document resume ed 082 610 he 004 614 weiss, carol h ... · chronology - phase iii 111 scoreboard:...
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DOCUMENT RESUME
ED 082 610 HE 004 614
AUTHOR Weiss, Carol H.TITLE The Consequences of the Study of Federal Student Loan
Programs: A Case Study in the utilization of SocialResearch.
INSTITUTION Columbia Univ., New York, N.Y. Bureau of AppliedSocial Research.
SPONS AGENCY Office of Naval Research, Washington, D. C. GroupPsychology Branch.
REPORT NO NO0-14-67A-0108-0006; NR-170-174PUB DATE Oct 70NOTE 147p.
EDRS PRICE MF-$0.65 HC-$6.58DESCRIPTORS Case Studies; *Educational Finance; *Federal Aid;
*Fiaancial Support; *Higher Education; SocialSciences; Student Costs; *Student Loan Programs
ABSTRACTThis report traces the consequences of a study of
federal student loan programs. The first chapter outlines the eventsthat led up to the Loan Study, the nature of the questions posed, andgovernment preparations for letting a contract for the study. Chapter2 describes the conduct of the Loan Study: the development of aproposal, the beginning of study activities, and the pursuit of twotracks of investigation. Chapter 3 traces the decisionmaking on thefuture of loan programs. The fourth chapter identifies factors thatfacilitated and constrained utilization of the Loan Study. Appendicesinclude related data. (MJM)
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COLUMBIA UNIVER,SITYtu-1
THE CONSEQUENCES OF THESTUDY OF FEDERAL STUDENT
LOAN PROGRAMS
A Case Study in the Utilizationof Social Reserareh
Carol H. Weiss
S DEPARTMENTOf NEAEINEDUCATIONg WELFARENATIONAL
:NSTITUTf OFEDUCATION
F ;-(
FILMED FROM BEST AVAILABLE COPY
BUREAU OF APPLIED SOCIAL RESEARCH
Columbia University605 West 115th StreetNew York, N. Y. 10025
The Bureau of Applied Social Research is an instrument of Columbia University'sGraduate Faculties for training and research in the social sciences. The Bureau has formany years served as the research laboratory of the Department of Sociology, and italso facilitates social research by students and faculty of other departments and schoolsof the University. The Bureau's governing board includes representative,, from all of theUniversity's social science departments and several professional schools,
The Bureau carries on a program of basic and applied research under grants andcommissions from foundations, government agencies, social welfare ' .,nd other nonprofitorganizations. and business firms. In so doing it provides experience on major empiricalstudies to graduate students and makes available data and facilities for student projects;it provides research facilities to faculty members; it offers training and consultation tovisiting scholars, especially from social research institutes in other countries; and it makesthe results of its investigations available through publications for lay and scientificaudiences.
A bibliography of Bureau books, monographs, articles, unpublished research reports,dissertations, and masters' essays may be obtained from the Bureau's Librarian.
THE CONSEQUENCES OF THE STUDY OF FEDERAL
STUDENT LOAN PROGRAMS
A Case Study the Utilization of Social Research
Carol H. Weiss
Document B of
The Columbia-ONR Project on the Uses of Sociology
Bur.eau of Applied Social Research
Columbia University
October 1970
TABLE OF CONTENTS
Acknowledgments
Introduction 1
Utilization: Search for a Meaning 1
Organization of this Report 4
Chapter I: Prelude to the Study 6
Origin of the Study 11
Chronology - Phase I 20Themes 21
Anticipated reliance 21Decision relevance 22Timing 23
Ground shift 23
The actors and their roles 24
Chapter II: Conduct of the Study 26
The Study Begins -- April 1967 26
Conduct of the Study: Track 1 -- the Bureau 26Conduct of the Study: Track 2 -- the CEEB 35
Merger of the Two Tracks of Investigation: The Recommendations 38
Influence of field work 39
The development of study recommendations 43Report of the Study 52
The relation of the recommendations to the questionnairedata 56
Chronology -- Phase II 64
Chapter III: Decisions Are Made 66Meanwhile at the Office of Education 66The Office of Education Goes on Record on the CEEB
Recommendations 73The Higher Education Amendments of 1968 77The House Subcommittee Uses the Report 78Senate Reception of the Report: Respectful but Uninterested. 85Action on the Higher Education Amendments 91
Short bill 91House passage of the big bill 95The Senate bill 99Interim extension 100
Passage of the Bill 101The Role of the Public Health Service 104The Health Manpower Act of 1968 107Chronology - Phase III 111Scoreboard: Did Survey Data Increase the Utilization
of the Study Recommendations? 112
Other Effects of the Study 115
Chapter IV: Concluding Comments 119
TABLE OF CONTENTS (continued)
Appendix A: Task Statement for the Study of Federal Loan Programs
Appendix B:
Appendix C:
Successive Drafts of Recommendations of the Study --October 9, October 20, December 4, Final Report
Forty-four CEEB Recommendations, Classified by Degreeof Survey Support
i.
ACKNOWLEDGEMENTS
The information in this report comes largely from the partici-
pants in the research and in its subsequent consideration for adminis-
trative and legislative decisicn-making. They were uniformly magnani-
mous with their time, information, and conmentaries. It would be hard
to imagine a more cooperative and insightful group of informants.
Deep thanks go to James W. Moore, Director of the Division of
Student Financial Aid, Office of Education; John I. Kirkpatrick, study
director, College Entrance Examination Board; Peter P. MuirheaL,
Associate Commissioner for Higher Education, Office of Education; John
F. Morse, director, Commission on Federal Relations, American Council on
Education; George and Patricia Nash, Bureau of Applied Social Research,
Columbia University; Charles Lee, professional staff member, Senate Sub-
committee on Education of the Committee on Labor and Public Welfare;
Roy H. Millenson, Minority Clerk, Senate Subcommittee on Education;
William Gaul, Associate General Counsel, House Committee on Education
and Labor; George Warner, Chief, Student Loan and Scholarship Branch,
Bureau of Health Professions Education and Manpower Training, Public
Health Service; David C. Bayer, Chief, Guarantee Agencies Section,
Insured Loans Branch, Division of Student Financial Assistance, Office
of_Education; Samuel Halperin, Deputy Assistant Secretary for Legisla-
tion, Department of Health, Education, and Welfare; Donald C. Parks,
Executive Officer, Division of Health Manpower Educational Services,
Bureau of Health Professions Education and Manpower Training, Public
Health Service.
For further information, we wish to thank Mrs. Betty Pryor, Com-
mission on Federal Relations, American Council on Education; Donald
Hirsch, Special Assistant to General Counsel, General Counsel's Office,
Department of Health, Education and Welfare; Mrs. Corinne Graves, Assist-
ant to Chief, Student Loan and Scholarship Branch, Bureau of Health
Professions-Education and Manpower Training, Public Health Service; Don
Berens, administrative assistant, House of Representatives Special Sub-
committee on Education; Ann Pasanella, Assistant Director of Research,
College Entrance Examination Board; Robert Barkley, former staff member,
Health Subcommittee, Senate Labor and Public Welfare Committee; James
Meager, professional staff member, House Interstate and Foreign Commerce
Committee.
I also wish to thank my colleagues on .he Utilization project
at the Bureau of Applied Social Research, particularly Professor Paul
F. Lazarsfeld for his stimulating comments and Joel Brooke for his
cheerful help.
Note: Positions and titles are given as of January 1969.
1.
IUTRODUCTION
Utilization: Search for a Meaning
The investigation reported in this paper is part of a project on
"The Utilization of Social Research." The intent of the project is to in-
crease our understanding of what happens to research studies after they
are completed. How are they "used?" Under what circumstances are they
uses? What problems interfere with their utilization?
in recent years, an increasing amount has been written on researh
utilization.* Scholars have analyzed the roles of social scientists,
speculated on the effects of the social organization of research, made
beginnings in the study of clients and potential users of research, their
values, valuations, communications behavior, and utilization activities.
Policy and operations in substantive fields have been examined in an
attempt to assess the contribution of social science research. Much of
the writing has been subjective, most of it impressionistic, a good
deal polemical.
From the welter of information and opinion, some critics conclude
that the pay-off of social research is small. At the extreme, some say
research is not only rarely utilized but rarely worth utilizing. Others,
more scholarly, are using the growing body of information to develop
*Three of the best recent anthologies are Paul F. Lazarsfeld, WilliamSewell, and Harold Wilensky (eds.), The Uses of Sociology, Basic Books,1967; Elisabeth T. Crawford and Albert D. Biderman (eds.), Social Scien-tists and International Affairs, Wiley, 1969; Research and TechnicalPrograms Subcommittee of the Committee on Government Operations, U. S.House of Representatives, The Use of Social Research in Federal DomesticPrograms, Dinetieth Congress, 1st Sessicn, Farts 1-IV, 1967.
2.
theoretical understanding of the processes of utilization, a sociology of
social research. Practical-minded writers are trying to extract princi-
ples that will increase the use of research. Lists of necessary pre-
conditions for use include suQh various items as close contact between
client and researcher during the study, the existence of an emergency
situation facing the client, availability of money and resources in the
user organization, attractive and competent presentations of results,
engagement of the researcher in post-research decision-making, and many
more.
With all the writing that has been done, it is surprising to
find that little actual research has been done on the extent to which
social research is used or what makes some research used and some
languish neglected. The most common discussion is still the case history
of research that the writer has been involved in. The prevailing tone
(despite all the recognition of external constraints) remains one of
hurt that research results were not more effectively applied.
That so little research on utilization has been done suggests
the complexities of such study, Lot only methodologically but conceptu-
ally as well. As Paul Lazarsfeld has said, utilization is an empty word.
What does it mean? Is the only bona fide use that which takes research
results and interpretations and applies them directly to the intended
practice or policy? But no research solves all the questions. Decision-
makers inevitably face dilemmas arising from cost, politics, timing,
public acceptance, sudden (post-research) changes, the application of
abstract propositions to a concrete situation. How much effect should
research have before it can be considered "used?" What of research thet
raises.new issues or leads to redefining of existing issues? Or research
3.
that leads to further research? What are the varieties of meaning that
inhabit the word "utilization"?
Are there non-scientific uses of research that deserve to be
considered utilization? Research can provide "social vindicators" for
a federal program. It can succeed in postponing an awkward problem, or
shunting responsibility for it. "Basic" research sponsored by a federal
agency can lend prestige to the grantors and encourage further Congres-
sional appropriations. The research has had utility. Its consequences
in the real world, however nonrational, have achieved some of the sponsor's
objectives. Where must research purpose and outcome intersect before we
can talk of utilization?
As one step toward specification of the meanings of utilization,
we undertook to trace the consequences of several research studies.
This report describes the consequences of one such study, "The Study of
Federal Student Loan Programs."
The Student Loan Study was conducted by the College Entrance
Examination Board with the assistance of the Bureau of Applied Social
Research under contract with the Office of Education.
As expressed in the task statement, this study was designed to
"gather information and evaluate factors bearing on the organizations
and operations of federally supported student loan programs. The evalua-
tion will cover administration of the student loan programs,.the problems
of student loan collections, and other significant areas of student loan
operations. In total, the study will develop and propose measures to
make federally assisted student loan programs best serve the Nation's
broad educational objectives."* The study began in April 1967 and the
*"Task Statement for the Study of Federal Loan Programs," Appendix A, inA Study of Federal Student Loan Programs, College Entrance ExaminationBoard, 1968.
4.
report was submitted to tie Office of Education in January 1968. The
budget for the study was $125,304.
Organition of This Report
The report is divided into four chapters. The first chapter out-
lines the events that led up to the Loan Study, the nature of the
questions posed, and government preparations for letting a Etntract for
the study. There follows a chronology of the events of the :nen Study
from its-gleam-in-the-eye stage to its impact on later events. The
chapter concludes with a discussion of the themes that appear in our
chronicle of utilization of the Loan Study results.
Chapter 2 describes the conduct of the Loan Study: the develop-
ment of a proposal, the beginning of study activities, and the pursuit of
two tracks of investigation. The two lineS of study merged in the develop-
ment of recommendations for government action and the preparation of the
study report.
Chapter 3 traces the decision-making on the future of loan pro-
grams. The first section describes steps taken in the Office of Educa-
tion while the study vas in progress. Following sections detail responses
to the Loan Study report and subsequent actions by the Office of Educa-
tion and the House and Senate subcommittees on education that culminated
in passage of new loan legislation, the Higher Education Amendments of
1968. Loan legislation in the health field is administered and legis-
lated by different bodies. Succeeding sections therefore, are devoted
to the responses to the Loan Study and activities of these groups--the
Public Health Service and the cognizant Congressional committees. The
chapter continues with an assessment of the effect of survey data on the
5.
fate of Loan Study recommendations for legislation. The final section
discusses non-legislative effects of the study.
The fourth chapter attempts to identify the factors that facili-
tated and constrained utilization of the Loan Study.
6.
CHAPTER I
PRELUDE TO THE STUDY
The mandate to "gather information and evaluate factors bearing
on the organization and operations of federally supported student loan
programs" involved six different loan programs in effect at the time of
the study.
In 1958 the Congress passed the National Defense Education Act.
Title II of the act established a program of long-term low-interest loans
to students in institutions of higher education who had financial need.
Under provisions of the National Defense Student Loan Program (NDSLP),
the federal government contributes 90 per cent of the principal and the
institution contributes 10 per cent. The program is administered federally
by the Office of Education through the Division of Student Financial Aid,
which distributes funds annually to colleges and universities. The
colleges lend the money and collect the loans.
Students with superior academic background receive special con-
sideration. Undergraduates can borrow up to $1,000 a year with a maximum
of $5,000. Graduate and professional school students can borrow up to
$2,500, with a maximum (including both undergraduate and graduate loans)
of $10,000. A loyalty oath is required. The student does not repay the
loan (and no interest accrues) until after he has terminated his educa-
tion. Repaynent is deferred and interest suspended during military ser-
vice, Peace Corps, and VISTA service. When the student has completed his
studies, he repays the capital and pays interest of 3 per cent per year.
In 1964, eligibility for loans under the NDSLP was extended to students
carrying at least half-time academic programs.
7.
For students entering the teaching profession, up to half of the
loan will be cancelled at the rate of 10 percent for each year of
teaching. Through 1965 and 1966 amendments, teachers in low-income
school districts and teachers of handicapped children receive cancella-
tion of the entire loan, at the rate of 15 per cent per year.
The program has been enthusiastically accepted and used by the
institutions of higher education and by students and their parents. Over
1 billion dollars in loans have been made to students at over 1700 schools.
As intended, the National Defense Loans have generally gone to students
from lcwer-income families* and enabled many to attend college who would
otherwise have been unable to meet the costs.
In 1961 and 1962 a special loan program for Cuban refugees was
enacted. In 1963 its terms were made to correspond generally with those
of the National Defense Student Loan Pro3ram, although with special
considerations. Administration is through the Office of Education, but
a segment is operated by the Public Health Service.
In 1963, the Health Professions Educational Assistance Act
authorized loans for students in medicine, osteopathy, dentistry, andsubsequent legislation added
/other health professions. The Bureau of Health Manpower of the Public
Health Service administers the program. Therewas a higher ceiling on
loans ($2,500 rather than $1,000 for any one academic year), interest was
higher (the "going Federal rate" set by the Secretary of the Treasury).
Forgiveness of the total loan was authorized for practice in a low-income
*Approximately 70% of borrowers were from families earning $6,000 ayear (..x less. Nash, George, "Student Financial Aid--College andUniversity," Encyclopedia of Educational Research, Fourth Edition.
8.
rural area, and forgiveness cf part of the loan for practice in an area
designated as having a shortage of the given professional service.
Loans for nursing students were authorized in 1964. The Nursing
Student Loan Program, too, is administered by the Public Health Service.
Borrowers who work full-time ac professional nurses in public or non-
profit institutions or agencies received cancellation of up to half the
loan at the rate of 10 per cent each year.
By 1965, the student loan structure was complex, but apparently
operating to the satisfaction of the students and the educational insti-
tutions. Howevert several important factors were pressing on the student
loan system. First, it was becoming clear that the amount of funds
wide available for loans would have to continue to increase drastically;
both the costs of education and the proportion of youth going on to
higher education were increasing over time. Second, the federal bud-
get--particularly with increasing defense appropriations for the Vietnam
conflict--was not likely to increase allocations for student loans at
anywhere near the needed rate. Third, there was a pervasive sense that
the private sector of the economy, in this case the lending institutions
of the nation, should participate in student loans. Lending money was
their business; through government reinsurance of loans, risk would be
eliminated, and the supply of money for educational loans would be
greatly expanded.
Another set of factors was operating. Middle-income parents
were asking for spine relief from the heavy expenses of higher education.
The then-current loan programs for undergraduates were for lower-income
people, but what about the $10,000 or $15,000 family with two children in
college at a cost of $2,000-$3,000 per year per child? Senator Ribicoff,
9.
among others, was pressing for tax deductions for families with children
in college. The administration opposed the plan, because the individual
family would recover only a small fraction of its outlay (and colleges
might well raise tuition, since the extra cost would be painless).
Treasury estimates of lost revenue by the second year reached $1.3-1.5
billion. The Treasury would consider the sum lost in taxes as financial
aid to students and could be expected to limit other aid programs, es-
pecially for low-income students.
To .1e-..t both sets of pressures, the Guaranteed Student Loan
Program (GSLP) was established in 1965. This program, rather than using
federal money, provided for government guarantee of loans made to students
by lenders. The federal government subsidized the total interest (set
at 6 per cent) during the student's enrollment in school and subsidized
half the interest (3 per cent) during the repayment period for students
with an adjusted family income of less than $15,000. Students from
higher income families paid full interest.
The GSL program was administered by state agencies, or in states
where state agencies were not yet operating, by a private agency under
contract to the government or to the Office of Education, or as a
last resort, under direct federal insurance program administered by
the Office of Education. The Office of Education advanced "seed money"
to state agencies to help them guarantee loans by banks in their state.
The Vocational Student Loan Insurance Act of 1965 provided an
insured loan program, similar to GSLP, to students in accredited public
and proprietary vocational schools.
The Guaranteed Loan Program did serve middle-income students
as intended. Of the loans processed by December 1967, half were made to
1C.
students whose families earned $6,000-$12,000 a year.
But in other ways the program fell short of expectations. The
states that did not have a functioning state agency prior to the enact-
meet of the federal program were slow in getting the program started
and any took no action at all. Lending institutions were far from en-
thusiastic about participating in the program. Money became very tight
jurt about the time that the program began operation (1965-66) and the
number of lending institutions making student loans was lower than ex-
pected.
But even before the Guaranteed Student Loan Program went into
effect, harrassed federal budget-makers saw the program as a way to re-
duce allocations for educational loans. In July 1965 the Bureau of the
Budget sent out an edict to government agencies preparing budget re-
quests for fiscal year 1967 to reexamine budgets carefully. If possible,
new programs that cost less money should be substituted for old programs.
The Bureau of the Budget people and the Department people in HEW realized
that the National Defense Student Loan Program and the soon-to-be-enacted
Guaranteed Student Loan Program were very similar and would in essence
serve the same purpose. In the fall of 1965, a decision was made high
up in HEW to replace the 1DSLP with the GSLP in order to save $190
million from direct appropriations. As a result HEW budgeted no money
for National Defense Student Loans in its fiscal year 1967 budget.*
Although there was great opposition to the termination of the NDSL
*For a full discussion of this act, its antecedents, and the controversyit engendered, see Basil J. Whiting, Jr., "The Student Loan Controversy,"Public and International Affairs, Vol. V, No. 1, Spring 1967, pp. 5 -12.
11.
Program within the Office of Education, the HEW budgetary proposal rep-
resented acquiescence to the Bureau of the Budget and the White House.
The private sector, through the GSLP, was to take over.
The outcry was immediate. The NDLSP had political sex appeal.
It had worked well since 1958, had about 1-1/4 million borrowers, most
of whom had voting parents. The American colleges--over 1600 of them
were participants in the program--rose up in righteous indignation.
They depended on the NDSLP. What about students currently on loans?
Were they to be cut off? There was no way of knowing whether bank loans
would work at all, and if that program fell flat, where would the stu-
dents and the institutions be? Letters poured in to the Congress.
Mrs. Edith Green, chairman of the House Special Subcommittee on
Education was particularly :angry. The National Defense Student Loan
Frogram,which had enabled over a million poor youth to attend college,
was one of the subcommittees favorite programs. Moreover, the Repub-
lican members of the House were not alsinclined to make political capital
out of the issue.
The Congress, largely through the efforts of Mrs. Green and.
Mr. Fogarty of the Appropriations Committee, restored the original level
of authorization ($190 million) for NDSLP. Actual appropriations were
$179 million, The Congressional move "broke the President's budget,"
i.e. appropriated more than administration requests. The President was
not pleased. He.was annoyed at HEW for leaving him in a politically
untenable position.
Origin of the Study
Secretary John Gardner of HEW was anxious to avoid traps of this
12.
sort again. Moreover, loan programs had gone into operation iii
health field and were being proposed in other areas, and as loan pro-
grams proliferated, he wanted information on which to base effective
planning. Both political and administrative consideloxions made a study
st-am usefUl. Secretary Gardner sent a memo to Commissioner of Education
Harold Howe II in spring 1966 asking for an outside study of federal
student loan programs, to be jointly financed by the Office of Education
and the Public Health Service. The Office of Education began to develop
plans for the study in spring and summer 1966.
It was in the same summer of 1966 that the Guaranteed Loan
Program was launched. It was also a time of tight credit. There was
some immediate feedback from irate parents that banks wouldn't lend
money. The Higher Education Amendments of 1966 included an amendment,
introduced by Senator Brewster of Maryland, directing the Commissioner
of Education to study the loan insurance program.
The Commissioner of Education shall make an investigation and studyto determine means of improving the loan insurance program...par-ticularly for the purpose of making loans insured under such programmore readily available to students. The Commissioner shall reportthe results of such investigation and study, together with hisrecommendations for any legislation necessary to carry out such,improvements, to the President and the Congress no later thanJanuary 1, 1968.
Because plans for a study of loan programs were already under
way, it was not necessary for the Office of Education to contract for
a separate study. Instead the GSLP, although very new, was included
in the study plans.
An advisory committee was set up within the Department with
representatives from the Office of Education, the Public Health Service,
and the Comptroller's Office, to define the study's tasks and recommend
13.
procedures for awarding the contract. Meetings were going on durin'
the height of the budget conflict, and it was inevitable that the commit-
tee was concerned with a shift to private funding of student loan pro-
grams, its feasibility, and the administrative burdens for the federal
government of auditing, accounting, and reporting.
Another topic that received considerable attention was the amal-
gamation of the adr&nistration of all six loan programs in one adminis-
trative unit. Secretary Gardner was pressing for greater order and
rationality within the jerry-built structure of the department, and
common administration of the loan programs seemed a reasonable move.
During the summer of 1966, the advisory committee drew up a list
of possible contractors for the study. Names on the list were largely
those of management consultants--Booz, Allen and Hamilton; McKinsey and
Co.; Cresap, McCormick, and Paget, etc. In the undated document that
lists these firms, the deadline for submission of st,.th proposals was
September 16, 1966. But talk in the department dragged on for months.
What James Moore, Director of Student Financial Aid, Office of Education,
calls "bureaucratic muddling" went on for the rest of 1966 concerning
just what the study should study and who was going to pay how much toward
its cost. In January and February 1967 final decisions were made. A
"request for proposal" (RFP) was written in the Office of Education.
The study was to look into matters of policy as well as procedures, and
a new Est of prospective bidders was drawn up. Non-profit agencies with
knowledge about education--rather than commercial consulting firms--were
asked to submit proposals. It was on this list that the CEEB was included.
A bidders' conterr)ce was held, and negotiations took place with a
number of agencies.
The task statement for the study outlined federal policy on
student loans:
14.
(11 the federal government has fostered student loans)to needy students and is now extending benefits of loans to students
from middle-income families "so that additional students will attend
college," and (2) "federal policy is to minimize direct loans financed
from the Federal Treasury, and maximize loans through private financial
sources," with federal guarantees and subsidies tc keep the cost to the
student low.
The objectives of the study, as stated by the Office of Educa-
tion, were to collect information about, and evaluate, the federal loan
programs--their organization, operation, and administration--in relation
to the policy guides given above. Furthermore, the study was to make
proposals for improving student loan programs.
Several key coverage areas were itemized. These included
(1) administrative structure, responsibilities, and relationships,
(2) operating responsibilities of the educational institution, lending
institution, and loan guarantee agency, (3) administration of student
loan forgiveness because of teaching, practice of medicine in rural
areas, or other public service which the Congress has determined to be
eligible for forgiveness, (4) factors affecting the supply of private
credit, (5) measures that will assure loans to applicants with financial
need under credit shortage conditions, (6) special problems of private
credit for minority groups and families without established credit
records. A pervasive emphasis is the transition to private funding of
the loan programs and the examination of arrangements that will ensure
fairness, efficiency, and operating harmony.
See Appendix A for the complete Task Statement for the Study.
15.
The CEEB Proposal
When the College Entrance Examination Board received the "re-
quest for proposal" from the Office of Education, staff evinced interest
in undertaking the type of study described. John I. Kirkpetrickodirector
of CEEB's Col.ege Scholarship Srvice, who was to become Study director,
made a pencil note, "We could use this to become experts in field."
Mr. Kirkpatrick and two other staff members of CEEB attended the
briefing meeting held on February 24, 1967 by the Office of Education to
discuss the projected study--the govarnment's concerns, issues to be
covered, financial arrangements, schedule and deadlines. It became
clear that OE expected a survey of collcges' experience with loan ad-
ministration and their opinions of improvements needed in the programs.
The meeting confirmed the CEEB staff's interest in undertaking the
study, particularly when OE's original deadline for completion of the
study was moved from September 30, 1967 to December 31, 1967.
The decision was made at CEEB to proceed with the proposal.
John I. Kirkpatrick would plan the study and write the proposal, since
federal loan programs were closely related to his responsibilities as
director of the College Scholarship Service. The major function of the
College Scholarship Service is the development and administration of a
system for determining the financial need of college students. It
reports the family's financial circumstances to the educational institu-
tions to which the student has applied.
Mr. Kirkpatrick was new to the position, having joined the staff
on February 1, 1967 with the title of Vice President. He was not new to
CEEB. He had been a Trustee, and for 16 years served as chairman of the
Finance Committee. His previous employment was largely in university
16.
financial administration- -as vice president and treasurer of Pace College,
vice president and treasurer of Lehigh University, and vice chancellor
for administration at the University of Chicago. He also had nine years
of banking experience with the Irving Trust Company.
A meeting was scheduled for March 3, 1967 between staff of the
CEEB and the Division of Student Financial Aid of the Office of Education
to continue discussions on the proposal. A few dais before the meeting,
Kirkpatrick called George Nash of the Bureau of Applied Social Research.
He told Nash about the projected study and asked if he would be interested
in working on the survey of colleges that OE wanted. When Nash expressed
interest, he was invited to join the CEEB delegation to the meeting on
March 3 with OE in Washington.
How did the Bureau of Applied Social Research come into the
picture? Paul F. Lazarsfeld, former director and chairman of the
Administrative Board of the Bureau, had long been a member of the CEEB
Committee on Research and Development. The CEEB and the Bureau had
worked together In previous studies. The most recent cooperative study
dealt with financial aid policies and practices and the emerging pro-
fession of financial aid officer.* George Nash, the Bureau director of
that study, thus had relevant survey experience in the financial aid
field and contacts with CEEB staff.
Nash was a sociologist. Working with him would be his wife,
Patricia, also a sociologist at the Bureau of Applied Social Research.
The Nashes had collaborated on a series of studies at the Bureau, on
*George Nash, with the collaboration of Paul F. Lazarsfeld, New Adminis-trator on C;0. s: A St of the Director of Under raduate FinancialAid, Bureau of Applied Social Research, 1 7.
17.
topics ranging from Skid Row to the Peace Corps to the reactions of
New Yorkers to the 1965 blackout.
On March 3, the meeting between OE and CEEB was held in the
office of the Director of Student Financial Aid of OE, James Moore.
Staff of the two agencies discussed the requirements of a study of the
loan field. The discussion was Nash's first exposure to the issues and
problems of the study. His notes of the meeting show the uncertainties
at this stage about how data shall be collected. The notes say:
"Could geld -feet send questionnaires [cross-out in original notes]
Could go back and do a group basis--based on tilt: results of thequestionnaires maybe
Personal interview50 interviews done x 10 people
Banks--group interviews"
In the following days, the proposal for th: study on student
financial assistance took shape Kirkpatrick leaned toward interviews
and conferences as the methods for data collection. Nash pressed for
the extensive use of structured mail questionnaires. His suggestion
that educational institutions be surveyed in toto, rather than on a
sample basis, was included in the proposal. Junes Moore of OE was also
in favor of the 100% sample of educational institutions. On the other
hand, Kirkpatrick in a letter dated April 28, 1967 to Robert P. Huff,
Director of Financial Aid, Stanford University, wrote: "I agree com-
pletely with you that we may get more wisdom and help from a hundred
wise heads than from 2800 wise and not-so-wise heads. The U.S.O.E.
asked us specifically to cover the entire waterfront, including un-
accredited and junior colleges . . ."
On March 7, CEEB called in a small group of educators and a
banker to talk over the study plans. Then on March 13, Kirkpatrick
submitted the proposal to the Office of Education, including a subcon-
tract to the Bureau for preparing and processing questionnaires. On
the same day Nash wrote a "proposal letter" to Kirkpatrick outlining the
work that the Bureau of Applied Social Research was prepared to do on
the questionnaires and giving a budget.
The CEEB proposal called for the collection of data and opinions
from (1) the Office of Education and the Public Health Service (PHS) in
Washington, (2) the regional offices of-HEW, (3) colleges and universi-
ties, (4) vocational schools, (5) schools of nursing, (6) medical and
other health professions schools, (7) state and private guarantee agencies,
(8) United Student Aid Funds, (9) lending institutions, and (10) students
and parents.
For the schools (3,4,5, and 6), the lending institutions (9),
and the students and parents (10), questionnaires were to be used.
But in none of these cases would questionnaires be the only technique
for collecting information. They would be "followed by in-depth personal
interviews where considered desirable and group meetings."* The question-
naires would be "prepared, followed up and processed by a professional
Bureau under the supervision of CEEB," while the "CEEB staff plus outside
consultants will handle the individual interviews and group meetings on
a regional basis."**
*CEEB, Proposal for Study Submitted to the U.S,. Commissioner of Educa-tion, "A Study of the Administration of Federally-Assisted Student LoanPrograms," March 13, 1967, Revised March 30, 1967, p. 10.
xxibid.
19.
The Bureau sub-contract was only in a limited sense to be a self-
contained study. CEEB saw the questionnaires rather as a technical
adjunctlwhich would then form the basis for meatier analysis through
interview and conference. For some respondents--for example, staff of
OE and PHS and state and private guarantee agency personnel--only inter-
views were planned.
The CEEB proposal outlined two phases of work to follow the col-
lection of information and, opinions. TV:se were, first, the interpreta-
tion of the data and the development of "a best set of plans" for
federal loan programs. This would be dons, through discussions with
representative groups of relevant institutions and agencies. Secondly,
the best set of plans would be presented to a National Advisory
Committee of the study for review and approval, and then to the senior
officers of CEEB for their review and approval.
The budget request was approximately $160,000. This exceeded
the $110,000 that the Office of Education had available. In negotiations
it was agreed to eliminate some of the review of administrative struc-
ture, reporting, and processing. Agreement was reached on a budget of
$125,000. The proposal was revised in accordance with the agreement
and re-submitted on March 30, 1967. On April 13, OE notified CEEB by
telegram that they had been awarded the study contract.
The CEEB then formally subcontracted the questionnaire survey to
the Bureau of Applied Social Research. The amount budgeted in the pro-
posal was $27,000; Nash's proposal letter, which Kirkpatrick now agreed
to, called for $27,600. (With the subsequent addition of questionnaires
to lebding institutions and to student borrowers, the total Bureau costs
would finally come to $35,000.)
20.
Chronology - Phase I.
The study was ready to begin. The following table summarizes the events
that led up to the start of the study.
Phase I. Prelude to the Study
Congress
1958-Enactment of NationalDOEbse Student LoanProgram (NDSLP)
1961-2-Student loans madeavailable for Cubanrefugees
1963-Enactment of HealthProfessions Student LoanProgram (HPSLP)
1964-Enactment of NursingStudent Loan Program (NSLP)
1965-Enactment of GuaranteedStudent Loan Program (GLP)
- Enactment of VocationalStudent Loan Program
1966-Congress renews NDSLPauthorization, overridingHEW.
- Brewster Amendment
calls for study of Guaran-teed Loan Program
1967
Office of Education
HEW agrees to Admin-istration budgetproposal that termin-ates NDSLP in FY 1967.
Secretary Gardner asksCommissioner Howe tohave an outside studymade of federal loanprograms.
HEW committee definesstudy tasks.
Jan.-Feb. OE writesRe's for Proposal,"
holds bidders' con-ference.
April-Contract issigned for study.
CollegeEntranceExaminationBoard
March-CEEBwritesstudyproposal.
Bureau ofAppliedSocialResearch
March-Bureauparticipatesin develop-ment of CEEBproposal.
April-CEEBsubcontractsquestion-naire surveysto Bureau.
21.
Them3
This was a particular kind of study, an investigation made to
order to answer fairly specific questions that the government had framed.
It was :Policy-oriented. It was expected to produce recommendations and
a set of plans.
Furthermore, it was to be largely a survey of experience and
opinf.on. The study was not to concern itself with the effects of the
loan programs. Except for the NDSLP, federal loan programs were too new
fcr 'there to be many effects to gauge. In order for the study to provide
information on the operation of the new programs, it would inevitably
rely on informal judgments.
With all its special features of origin, time, and purpose, the
life history of the study illustrates some issues in research utiliza-
tion that appear to be endemic. Four of these issues that will appear
in the narrative deal with: the seriousness with which the client
anticipates relying on study results, the study's relevance to the
issues on which decisions will be made, the timing of the decision-
making calendar, and the shift in issues and circumstances that occur
- while the study is in progress.
Anticipated reliance. The use of research to postpone a decisionenough
is a common/phenomenon to have passed into folklore, second in importance
as a delaying tactic only to appointing a committee. But there are
cases where the client awaits the results of a study impatiently so
that he will know what action to take. In between the extremes, there
are all shades of anticipated reliance on research. In this study, the
seriousness of intent was clear. The policy-makers were the clients for
22.
the study. Both the Office of Education and the Congress awaited the
results, if not breathlessly at least with clear interest. As we shall
see, the House Special Subcommittee on Education prodded the Office of
Education for release of the report. No one was prepared to accept the
study uncritically, but all the actors were anxious to listen. There
was general confidence in the expertise and otjectivity of the College
Entrance Examination Board and its prestige in the education field.
However, reliance on the study was tempered by another factor- -
the plowed field phenomenon. Many issues of the study had been around
for a long time and the ground had been plowed over and over. Most
decision-makers had pretty well crystallized their opinions (although
the crystallized opinions differed). Unless new information was forth-
coming, which wasn't too likely in a study of existing opinions, the
latitude for change was small.
Decision relevance. That there was a decision to be made was
indisputable. New student loan legislation would almost certainly be
passed by the Ninetieth Congress, and the whole gamut of legislative
provisions would be reviewed.
The translation of the issues into answerable questions is often
a phase at which things go awry. There nay be a shift away from the
matters that decision-makers want to know toward concepts that are
theoretically interesting or easily measurable. Here the translation
was routine. No sociological concepts, no theoretical constructs, were
involved. The Office of Education wanted to know, for example, if there
were special problems in assuring private credit to minority groups,
and the questionnaires asked both lending institutions and educational
institutions, "From the experience of your institution, how much trouble
23.
do racial minority group students have getting guaranteed loans (of those
who are legally eligible for them)?"
Another kind of problem of relevance did arise. The Bureau
surveys relied to a large extent on the opinions of officials in educa-
tional institutions and lending institutions. On controversial questions,
decision-makers raised questions about the worth of these opinions.
What they wanted was hard evidence of effect. Thus, for example, the
surveys produced data on what people thought the maximum total of loans
for a student should be. But key people discounted such "data." They
wanted to know what the effects of loans of different amounts were on
the postgraduate lives and careers of different kinds of students.
Timing. Research results and decisions have to match up in
time. Here, the timing of the study was out of phase in terms of the
legislative planning cycle. The months that were lost at HEW in late
1966 planning the study put the study about four months behind the major
decision-making for legislative proposals. Even as it was, the study
was overly rushed, foreclosing any opportunity to do more intensive
research.
Just as the over-all study was on a hectic schedule, so was the
Bureau questionnaire survey. It produced its data in remarkably short
time, and the marginals were used in developing final recommendations.
But the cross-tabulations were completed at a time when little attention
could be devoted to them.
Ground shift. One of the more interesting phenomena that the
Loan Study illustrates is the change in issues while a study is in pro-
gress. The ground shifts, the questions originally considered of pri-
214.
mart' significance are resolved or disappear, and new issues take their
place. By the time the report produces data and recommendations to solve
the original problems, the problems are no longer the relevant ones.
Here, the major legislative issue motivating the study was the
search for a way to phase out the National Defense Student Loan Program
in favor of the all-private Guaranteed Loan Program. Political shifts
removed the issue from consideration. Similarly, the primary adminis-
trative issue at the outset was consolidation of administration of the
loan programs. Secretary Gardner saw this as one maneuver in his mis-
sion to bring rationality and streamlined procedures to HEW. But staff
committees met on the question while the study was in progress, and
before CEEB completed its report, they decided to let the existing
division of authority stand. The study did not catch up with the
ground shift. Further, new issues came to the fore, such as what to do
about loans held by student demonstrators and rioters, issues that were
unforeseen in the study.
Even for research as compressed in time as this was--completed
in nine months--the busy-ness in the field of study left it behind on a
number of issues.
The actors and their roles. Another theme that emerges from the
history of the study is the manner in which utilization of a study is
influenced by the roles and the goals, the backgrounds, responsibilities
and concerns of the different individuals concerned with the production
and use of the data and the findings.
The CEEB study of student loan programs offers us special ob-
servational advantages because of the variety of people and roles in-
25.
volved in its production and utilization. There were Kirkpatrick at
CEEB, Nash at the Bureau of Applied Social Research, Howe, Moore, and
others at the Office of Education, Lovett and Warner of the Public
Health Service, the members of the House and Senate subcommittees on
education and the committee staffs. Final decisions on enactment of
new legislation would be made by the whole Congress.
One of the aims of the history which follows will be to show how
these different people reacted to and used the same data, in whole or
in part, in different ways. In presenting this story considerable
emphasis will be put on the data resulting from the questionnaires
administered by the Bureau of Applied Social Research. It sho 13 -be
understood that this is not because these data had special significance
in comparison to the research data produced through personal interviews
and meetings. Our emphasis is on the questionnaire data, because, like
irradiated injections, they are more readily identified and their
paths are easily traced.
26.
Chapter II
CONDUCT OF THE STUDY
The Study Begins -- April 1967
Kirkpatrick had several immediate matters to handle: recruiting
staff for the study at CEEB and setting up the National Advisory Com-
mittee for the Study. Because of the time limits of the study, he
turned to part-time consultants to do much of the staff work. These
were largely knowledgeable people in the college loan field. They were
supplemented by members of CEEB's regional offices.
The Advisory Committee, which was scheduled to meet twice to review
the reports that would emerge from the study, was recruited from top
figures in educational administration, banking, and related fields. As
finally constituted, it was a prestigious body of 23, including college
presidents, bank presidents, and an MIT physicist who headed the Panel
of Educational Innovation of the President's Science Advisory Committee.
Work on the study began along two tracks. CEEB staff met with the
Bureau of Applied Social Research to develop the survey questionnaires.
Simultaneously, the CEEB began arrangements for its own data gathering
through conferences and interviews to be run by its staff consultants.
Conduct of the Study: Track 1 -- the Bureau
The Nashes worked rapidly on the questionnaires. After review of
the OE "task statement" and discussion with Kirkpatrick, they produced
a draft questionnaire for colleges on April 15. This draft, eleven
27.
pages and 60 questions long, inquired into policies and practices for
all loan programs, with particular attention to Guaranteed Student Loans.
Kirkpatrick circulated copies for comment to over two dozen advi-
sors. These included staff at the Office of Education and Public Health
Service, CEEB staff in regional offices, members of CEEB committees, and
experts in specialized fields (e.g., nursing loans). A few of the
advisors were uneasy about the use of financial aid officers as infor-
mants on both the institution's administrative practices for federal
loan programs and views on how the programs could be improved. "I doubt
that the financial aid officer is always best to do either," wrote one
educator.
Another called the draft questionnaire "fairly superficial and
very applied in its orientation," and he questioned whether such ques-
tions as those dealing with the type of students likely to be delin-
quent in repayment would be answered from "systematically examined
records of delinquent students, or are the respondent's prejudices being
plumbed?" Other advisors were more positive about the questionnaire
approach. Many submitted detailed comments question by question. These
ranged from the recommendation to omit questions on characteristics of
financial aid officers and questions on the institution's organizational
structure for aid, to technical suggestions for classifying responses
about satisfaction with the National Defense Student Loan Program (very
satisfactory, somewhat satisfactory, somewhat unsatisfactory, very
unsatisfactory, can't say). Kirkpatrick marked up his own copy freely.
Separate questionnaires were developed for nursing schools, health
professions schools (medicine, dentistry, etc.), and vocational schools.
28.
Kirkpatrick and his staff conferred with accrediting groups for each
type of school, and brought on expert consultants to review the ques-
tionnaires in terms of their relevance and utility for the specialized
schools.
They held further conferences in Washington with James Moore and
his staff in the Division of Student Financial Aid on the college ques-
tionnaire. Out of all the review activity, important suggestions
emerged. In response, the Nashes made extensive revisions in the ques-
tionnaires. Items were dropped, combined, rewritten, added, But the
tenor of the questionnaires did not basically change. They remained an
inquiry into practices, opinions on strengths and weaknesses of the
programs, and opinions on suggested changes.
During the revisions, Kirkpatrick offered a different type of sug-
gestion. Rather than limiting investigation to reactions to existing
programs, the questionnaire could include a "Master Plan" for federal
student assistance. Respondents would then be asked for their opinions
on its features. and their probable actions under its conditions.
Given the Office of Education "Task Statement for the Study" (see
Appendix A), such an approach appeared sensible. The Office of Educa-
tion was laying as much emphasis, or more, on proposing measures for
the future as on studying experience in the past. If there were a good
idea for a "Master Plan" to start with, the responses of colleges and
banks could assess it, elaborate on it, and improve it. The new plan
could be pretested in the questionnaire.
Kirkpatrick laid out the features of such a Master Plan. A key
aspect, given the then federal policy of minimizing direct loans
29.
financed from the Treasury, would be the substitution of the Guaranteed
Loan Program for all other programs. The other main,features were drawn
from the North Carolina system, in which banks made a pool of money
available to the state agency, and the state agency actually administered
the loans.
Kirkpatrick tried to formulate questions around the Plan. On
April 20, he drew up the following questions:
REVISION (4/20/67) OF QUESTIONS ON PAGES 10-11 OF USOE QUESTIONNAIRE
We should like to have your advice concerning the feasibility anddesirability of a hypothetical plan.
SUPPOSE: (1) That new funds were no longer available for the NDSLprogram.
(2) That the Guaranteed Loan program were set up with thesame policies and procedures as NDSL.
(3) That the Guaranteed Loan program were financed centrally(by states, for example) by a pool of credit suppliedby banks, credit unions, insurance companies, etc.
(4) That your institution applied for and received a cer-tificate of entitlement providing for an allotment offunds.
(5) That your institution determined the amount of the loanfor each student.
(6) That your institution forwarded the loan papers andnotes to the central agency, for which in return youreceived the actual funds for crediting to students'accounts and/or turning over to students for variousexpenses.
(7) That the central agency undertook the responsibilityfor the collection of the loans.
In connection with the above hypothetical plan, please give your pre-liminary opinion in answering the next three questions. Your answerswill be considered as opinions only, and definitely not as commitmentsin any way.
30.
10. Would your institution deposit with the central agency a matchingamount of 10 percent of the loan funds received by you, as youpresently provide under NDSL, to bear a share of losses caused bydefaults in payment?
1. ( ) Yes 2. ( ) No 3. ( ) Don't know
11. If the answer to #10 is not "Yes," would your institution deposit5 percent?
1. ( ) Yes 2. ( ) No 3. ( ) Don't know
12. Would your institution be willing to contribute a small amount(perhaps $1 or $2 per loan) each year to the central agency tohelp carry the administrative costs of receiving, disbursing, andcollecting the loan funds?
1. ( ) Yes 2. ( ) No 3. ( ) Don't know
13. Please give us your opinion as to the acceptability of assumptions2 through 7 listed above, and as to what weaknesses there are inthis hypothetical plan.
The Master Plan question satisfied no one. The question could not
take account of all the possibilities, the if's and when's for, different
kinds of schools in states with differing state agency arrangements.
The whole idea of getting assessments of a new plan began to seem less
useful when the necessity of specifying all the conditions was faced.
Kirkpatrick and Nash abandoned the question and the Master Plan.
Instead, the research would limit itself to past experience and assess-
ments of plans already in operation and derive its proposals from analy-
sis of experience.
The Bureau continued its close consultation, item by item, with
CkEB and then with the Office of Education as well. In the collabora-
tive effort, six questionnaires were developed, pre-tested and sent out.
Questionnaires were mailed to 2,444 colleges and universities, 325 voca-
tional schools, 195 health profession schools, 532 nursing schools and
31.
2,112 lending institutions. This included every institution of higher
education in the country, vocational schools in the eleven states where
a substantial number of guaranteed vocational student loans had been
made (all the proprietary vocational schools and half of the public and
non-profit schools in those states), all medical, pharmacy, dental,
optometry, osteopathy, and podiatry schools, a sample of collegiate,
hospital, and graduate schools of nursing, all large commercial banks
and a sample of other commercial banks, savings and loan associations,
mutual savings banks, and credit unions. Kirkpatrick played a large
role in securing cooperation, and help in developing the sampling scheme,
from the National League for Nursing, accrediting groups for business,
home study, and technical schools, and the American Bankers Association.
In addition, a pilot study was done of student borrowers of the
class of 1965 in the New York metropolitan area. Kirkpatrick convened
an advisory group, called the Task Force on Student Attitudes toward
Borrowing, which met to advise on the development of this survey.
Questionnaires were mailed to 285 graduates who were paying off their
National Defense Student Loan Program (NDSLP) loans, and 109 were
returned. The results of this small-scale study were not available
until February 1968, a month after the final report was submitted, but
they were appended as a final chapter.
The first questionnaires began to go out in May. By June, TOO
returns had come in from educational institutions. Nash had them coded
and tabulated, and sent the basic figures to both the CEBB and the
Office of Education before June was over.
32.
Nash devoted considerable time to analysis of the data. He pro-
duced cross-tabulations of responses by over a dozen different variables.
Since almost none of these analyses were used or even referred to in
later deliberations by CEEB staff on the study and its recommendations,
it may be interesting to find out how they came to be done.
In Nash's original letter to Kirkpatrick on March 13, 1967 outlin-
ing the tasks that the Bureau was prepared to assume, he stated that he
would produce "marginals" (the total answers to each question) and
"certain, specified cross-tabulations" (breakdowns by such variables as
type of institution and size of institution) of the responses to the
questionnaire. His letter stated, "We will not do an exhaustive analy-
sis."
During the summer of 1967, at least three different conferences
between Nash and Kirkpatrick and Tom Brennan of the CEEB study staff
discussed which cross tabulations should be run. Nash remembers that
Kirkpatrick and Brennan requested the cross-tabs. There are notes in
the file of a meeting of Nash, Kirkpatrick, and Brennan on August 4
that list the cross-tabs agreed upon. The notes are in Kirkpatrick's
handwriting. They include (for educational institutions) type, control,
accreditation, enrollment, types of loan programs participated in, NDSL
repayment delinquency rate, state,OE region, and for all GSLP questions,
state and type of state guarantee plan. Other variables were added
subsequently, such as per capita state income, time devoted to aid by
financial aid director, satisfaction with GSLP.
That Kirkpatrick and Brennan were active in selecting these vari-
ables is obvious, but whether they actually initiated the extensive
33.
data analysis is not so clear. Neither man was a researcher by train-
ing or experience, whereas Nash came from Columbia's Bureau of Applied
Social Research with its tradition of sophisticated data analysis.
Nash ap.)arently assumed that anybody would want to look at the responses
in the context of relevant characteristics of the respondents, and asked
not "Do you want any cross-tabs?" but "Which cross tabs do you want?"
Many of the results of the analysis are informative. For example,
they show the differing characteristics of schools that were most and
least satisfied with the NDSLP and GSLP." But these differences did
not enter the discussions or seem to affect the formulation of recom-
mendations. A possible exception might have been the issue of loan
cancellation for students who subsequently became teachers. This was so
controversial that Nash recommended, and Kirkpatrick was happy to
accept, further runs identifying supporters and opponents of the prac-
tice. These runs were considered and quoted in the CEEB final report:
... A total of 34 percent of all respondents including 58 percentof the public universities responding to the questionnaire, statedthat in their opinion the teacher cancellation provision had notincreased the number of students in their institution who havegone into teaching. Of the respondents from teachers colleges,38 percent concurred in this judgement.
But as we shall see, the analysis by type of school did not have
much effect on the recommendation which CEEB developed on the issue of
cancellation.
*George Nash and Patricia Nash, "A Report of the Opinions and Practicesof College Student Financial Aid Administrators and Bankers on theFederal Guaranteed Loan Program," November 1967, mimeographed.
34.
There was another phase of the analysis that Nash believes might
have altered the relevant recommendation in CEEB's final report, had it
been taken seriously. This was the analysis of the success of tte
Guaranteed Loan Program (according to reports of schools and banks) by
type of state agency. The data showed that the GSLP was apparently not
performing well in a number of states with strong independent agencies.
The creation and strengthening of an independent state guarantee agency
did not appear to be the cure-all that the study recommendations would
imply. But even when the data for each state and type of state agency
were later discussed with Kirkpatrick, he was not convinced that Nash's
interpretation was the only one possible, e.g., students go to school
across state lines, and reports from an Illinois financial aid officer
about students' difficulties in getting guaranteed loans may refer to
difficulties in their home states, rather than in Illinois.
Why weren't the analytic data better used? Partly it was a matter
of time, pressure, and rush. Possibly also it was a matter of complex-
ity. There was great diversity by state and type of inEtitution.
Patterns did not come through clear and clean. Finally, it was a matter
of fit. CEEB was focusing on the development of across-the-board recom-
mendations that would influence legislation and policy. In the formu-
latisn of general recommendations, there was little room for analytic
particulars. What difference did it make if private universities feel
College WcA-Study is less successful than do other schools, or more
2-year colleges find collection of loans a major problem? The recom-
mendations, as envisioned by CEEB, could not deal with this kind of
35.
variation.* It would only be later, when the reports on each loan pro-
gram reached the federal administrative agencies, that program operators
would be concerned with such details.
Conduct of the Study: Track 2 -- the CEEB
CEEB meanwhile was pursuing other data collection activities. A
large part of the CEEB inquiry dealt with issues not covered by the
Bureau surveys. For example, CEEB called together a task force to plan
interviews with directors of state guarantee agencies. The focus of
inquiry was state practices. The five-man task force met on May 15,
1967 to decide on the kinds of questions to be asked and the procedures.
Subsequent discussions were held with CEEB staff and with George and
Patricia Nash. Some standardization was introduced into the interviews.
An interview schedule was written for state agencies with questions on
state operations, problems, and opinions regarding proposed modifica-
tions in the Guaranteed Loan Program. Interviewers tended to use the
schedule as a general guide rather than as a structured research instru-
ment.
Ten consultants conducted the interviews with directors of state
guarantee agencies in 48 states and the District of Columbia. The
records of the interviews went to consultant Jack B. Critchfield, dean
of student affairs at the University of Pittsburgh and chairman of the
task force on state agencies. On August 25, 1967, he submitted a
*The situation here illustrates one aspect of "decision relevance."Some of the survey analyses may have had relevance to issues in theloan program field, but they were evidently not seen as relevant byCEEB in preparing its report and recommendations.
36.
54-page "Summary Report of Interviews with State Loan Agencies." The
narrative report focused mainly on issues of state operations (e.g.,
how the agency was established, actual administration of the loan pro-
gram, state relations to the private United Student Aid Funds). It was
a descriptive report of the interview replies, focusing on the effects
of the different structural arrangements in the states. The basic con-
clusion in the report was that state administration of the loan plan is
conducive to efficient operation and proper functioning. With a better
return to banksoand streamlined administrative procedures, there will
be sufficient private money to enable the Guaranteed Loan Program to
serve effectively.*
Kirkpatrick and his consultants also held interviews with govern-
ment staff and representatives of agencies and interest groups involved
in loan programs. For example, in July he met with James F. Kelly,
Comptroller of HEW, to discuss such issues as use of the FNMA-type of
revolving fund to finance loans (a proposal then being made by the
TreasurytE forward funding by Congress, and the relations among the
federal government, states, universities, banks, and students. With
Charles Walker of the American Bankers Association he discussed a
financial need criterion for GLP, the success of the program, and ABA
promotional efforts to increase bank participation. He talked to
Edward W. Brice, assistant to the Assistant Secretary of HEW for Educa-
tion, about making loan provisions consistent in all programs. He and
*Jack Critchfield, "Summary Report of Interviews with State LoanAgencies," August 1967, page 54.
**The Allied Health Professions Personnel Training Act, passed inNovember 1966, had authorized FNMA -type funding for health professionsand nursing loans, The first funds under this provision were disbursedin August 1967.
37-
the study staff met with officials at the Bureau of the Budget, held
over a dozen conferences at the Office of Education, read extensively
in the financial aid literature. The Office of Education opened up its
files on the loan program to them, and provided statistical reports and
new tabulations of data.
The issues that were engaging their attention through the summer
were largely administrative questions. But inevitably there was overlap
with the questions of the Bureau surveys.
A major activity of CEEB was the convening of seven one-day con-
ferences in states around the country. The first one was in Raleigh,
North Carolina in August, and was attended by high-level bankers,
educators, state officials, and foundation representatives. Conferences
followed in Harrisburg, Pa., Denver, New York City, Syracuse, San
Francisco, and Chicago. At each meeting, influential representatives
from education, banking, state guarantee agencies, and related groups
deliberated for a full day over the issues in the field. Discussions
ranged over past experience, future expectations, and suggestions for
improvement in the program. No record was made of the proceedings.
Kirkpatrick was at every meeting, and found them important in
forming his ideas. Looking back after the study was over, he said,
"Here's where we learned so much about feelings about the Guaranteed
Loan Program."
Several additional conferences were also held, such as the August
conference with college and university business officers and the meeting in
October of the Committee on Governmental Relations of the National
Association of College and University Business Officers. A meeting
38.
that Kirkpatrick remembers as particularly informative was the National
Conference of Executives of Higher Education Loan Program, attended by
representatives of 26 state loan agencies. "These men," he said,
"lived with the loan program every day of every week for ten years or
more in some states. They ate, drank, and slept it. If they didn't
know, vrho did?"
The CEEB collected a great deal of information and opinion. The
.unfortunate fact, from our point of view, is that very little of it was
recorded. Only an occasional interview was written up, and none of the
major meetings and conferences (except the Advisory Committee on the
Study) has minutes on record. While Kirkpatrick gave us free access to
pore over all his files on the study, it was possible to discover only
fragments of the substance of the discussions and very little about
what the CEEB staff learned.
Merger of the Two Tracks of Investigation.: The Recommendations
In the fall of 1967, Kirkpatrick and his staff began to plan their
report to the Office of Education. By early October, they had in hand:
computer tables on the questionnaire responses of most schools and
banks, some of the cross-tabulations of the questionnaire data, Critch-
field's report on the interviews with state agencies, the experience of
seven state meetings which had been held in all parts of the country
(the last on October 4 in Chicago), plus the results of their own inter-
views.
On October 9 Kirkpatrick drew up a five page draft summary of the
strengths and weaknesses of the Guaranteed Loan Program. It would be
39.
enlightening if we could dye-mark the various pieces of evidence and
trace them into the summary. Unfortunately, no such clear-cut identi-
fication is possible. But while we cannot tell which specific items
of information affected each recommendation, we can gauge the general
effects of the different sources of evidence.
Influence of field work. Despite the reluctance of informants to
pinpoint the specific data that affected the formation of their opinions,
it way be useful to speculate on the ways in which the CEEB field work
influenced the development of recommendations. In many research
studies, the study director is in a similar position to Kirkpatrick's,
weighing different types of evidence, experience, preconceptions, and
non-research factors in the process of drawing implications for action.
Users of research studies, too, have to weigh various research and non-
research factors in reaching decisions about the action to take or
recommend. Perhaps future studies can inquire more closely into the
process by which these conclusions are reached.
Certainly cognitive background and experience play a part. Kirk-
patrick's experience in banking and university business administration
had given him knowledge of the loan field and insight into the perspec-
tives of significant actors in the system. He was intimately aware of
business and efficiency factors and the importance of sound use of
government funds.
The directness and personal involvement that field interviews and
conferences entail are often highly important. Field interviews cam:
(a) sensitize the study director to those particular issues that
his respondents forcefully present;
140.
(b) affect the kinds of questions which he will later ask in the
more structured data collection phases;
(c) influence his preconceptions of how the data will fall and
subtly build up a preference to emphasize those items of research data
that accord with his preconceptions;
(d) affect his assessment of the relative importance of issues;
and
(e) acquaint him with the political feasibilities, the constraints
in the system, and the limits within which his recommendations should
fit if they are to stand a chance of prevailing.
In this case it is clear that over all, Kirkpatrick gave greater
weight to the field work than to the questionnaires. Field interviews
did sensitize him to issues, affect his weighting of issues, and
acquaint him with political limitations. They had some influence on
the development of questions in the questionnaires, inasmuch as much of
the very etrly field work directly dealt with discussions and criticisms
of the draft questionnaires. The field work was influential, too, as
we shall see, in determining which items of questionnaire evidence
were taken seriously, cited,and relied upon in the final report. The
questionnaire data were used to a large extent as back-up data for
positions that emerged from the whole range of data collection activi-
ties.
The field interviews appear to have been particularly influential
in the assessment of the relative importance of issues. The question-
naires--and Nash, who relied largely on the questionnaires for his
informationmere limited to the questions as asked. Kirkpatrick and
the CEEB study staff sometimes felt that the Bureau was stressing unim-
portant points and blowing up small pieces of survey data into "revealed
truths."
With regard to learning about the political climate of opinion,
Kirkpatrick believes that the field work did enlighten them about polit-
ical feasibilities. However, he felt it imperative to call the shots
as he saw them. While he recognized the resistance in Washington to
such ideas as consolidating the administration of all loan programs or
introducing a financial need criterion into the Guaranteed Loan Program,
he believed that the study should develop and abide by its own convic-
tions.
In June 1970, about two and a half years after the study had been
completed, Kirkpatrick reviewed the experience and said:
If you made me come up with a percentage on importance of thequestionnaire data, I would say the questionnaire data were some-thing between a 20 and 25 per cent factor on the report. Theother 75 to 80 per cent were interviews, opinions, conferences,talking to people, going right to the top.
Because he was extremely busy right after the Loan Study and unavailable
for more than brief discussions with us then, it is impossible to know
whether his estimate would have been the same at a point closer in time
to the events.
Kirkpatrick explained his reliance on the interview and conference
material on several grounds. The participants in the conferences were
knowledgeable and important people. They had been chosen for their
expertise. Some, like Morse of the American Council on Education,
"lived and breathed educational legislation." Particularly on the
Guaranteed Loan Program, they knew vastly more than most college
42.
financial aid officers, who had not been directly involved in the pro-
gram. Because in the GLP students dealt directly with banks, college
aid people could give only a very partial picture of the program's
operation.
Secondly, personal contact is likely to have greater impact. Face-
to-face interaction can intensify communication. Long after the study
was completed, Kirkpatrick still remembered "a red-headed chap from
Illinois State Teachers College at the midwest conference who pooh-
poohed the idea that loan cancellation had any effect on the number or
quality of students going into teaching." He recalled, too, his amaze-
ment when the staff at the Office of Education told him what a heavy
percentage of their time they spent on clerical correspondence regarding
the definition of eligibility for teacher cancellation.
Further, interviewing is two-way communication. If a respondent
does not understand a question, if he misinterprets or gives a partial
answer, the interviewer or conference participant is not limited to the
first answer (as is a questionnaire). He can rephrase and reinterpret
the question. He can also explore different aspects and factors in
the situation and increasingly specify the direction, intensity, and
conditional limits of a person's knowledge and opinions. Question-
naires, on the other hand, may be answered superficially and with little
thought.
Another possible effect of field work is that it develops a collec-
tive sense of events among the study staff and brings about a "team
consensus." As staff continue their rounds of interviewing, telephone
calls, and meetings, they confer among themselves, sharing their
43.
experiences and building up a common body of information, knowledge-
ability and opinion. There are suggestions that this in fact did occur
to some extent among CEEB study staff.
While the over-all salience of the CEEB field work seems clear, it
is still difficult to tell which sources of evidence influenced each
specific recommendation. Kirkpatrick, for all his subsequent devalu-
ation of the questionnaires, in the fall of 1967 was paying attention
to the survey tables as Nash delivered them. They were bringing
organized and systematic data to the project.
The development of study recommendations. Nash was in and out of
the CEEB office in late September and early October (and on through the
next two months as well), delivering the latest tables hot off the
computer. Nash reports that the tables as such were almost never
discussed, so that it was hard to tell how they affected Kirkpatrick's
thinking. Kirkpatrick reports that he was being given reams and reams
of uninterpreted computer runs. Some discussions on particular issues
went on, and joint meetings of CEEB and Bureau staff were scheduled
for October.
On October 9, CEEB and Bureau study staffs met together specif-
ically to discuss the report that would soon be due on the Guaranteed
Loan Program. Kirkpatrick distributed the summary that he had prepared
of the program's strengths and weaknesses. In this material, the idea
appears of separating loans of necessity for the needy from loans of
convenience for the middle-class. There is also the same stress as
will appear in the final report on the desirability of a financial need
144.
criterion for Guaranteed Loans and of involvement of the colleges in
deciding on need and amount of loan. The summary also mentions the
unprofitability to lending institutions of 6 per cent loans, and the
unavailability of Guaranteed Loans to many students because of non-
participation of many banks, limits on availability of funds, require-
ments of an established account or relationship with the bank, state
residency requirements, and reluctance to lend to low-income and minor-
ity students. Another theme that will appear in the final report is
also briefly present: the negative effects of direct federal insurance
(which is provided when there is no effective state plan) upon states'
willingness to appropriate funds for state agencies. (Appendix B pre-
sents these recommendations and the successive versions of them in the
following three drafts.)
The staff discussion went on most of the day of October 9th. The
six CEEB participants and the Mashes hammered out twenty-four recommen-
dations, or, if the recommendation itself was not clear, areas in which
recommendations should be made. Almost all of the important recommen-
conceraing the Guaranteed Loan Program that were to appear in
the final report were agreed to at this meeting: financial need should
be a criterion for Guaranteed Loans; loans of necessity to the needy
should be separated from loans of convenience to the non-needy, and the
latter should not be charged as a federal aid to higher education nor
compete for federal funds for education; banks should receive a higher
return on Guaranteed Loans.
George and Patricia Sash, the Bureau staff members in their role
as suppliers of questionnaire data, were uneasy that the CEEB people
45.
were reaching conclusions without adequate attention to the question-
naire responses. They felt it their responsibility to refer to those
data when issues came up, and to convince the CEEB staff to do likewise.
But through this and most other joint meetings, there were almost no
substantive disagreements. Where the CEEB staff was taking positions
that were not based on data, Nash was willing, after pointing out the
absence of data, to discuss their position on their own terms.
Researchers usually expect to have recommendations developed out of
the results of their research, rather than being drawn up independently
while the research is in progress. They see a logical progression:
(1) data
(2) elaborated analysis of data
(3) conclusions based on the analysis
(4) action recommendations based on the conclusions
In this case, the data and some beginning analyses were ready although
there had not been time for the researchers to go further. But the
joint CEEB-Bureau group was starting with recommendations, going to the
data, and back to the recommendations. The best that Nash could do was
be sure that the early recommendations were checked against the data
for consistency. His position was--figuratively and often literally- -
to move the piles of computer tables to stage center.
TV fact that there were so few disagreements between the recom-
mendations that the CEEB study staff offered and the questionnaire data
is probably due to two main factors. First, the CEEB staff had been
talking with key people from the same groups (educational institutions,
lending institutions) that the Bureau was systematically surveying.
46.
They were receiving much the same kind of information that the question-
naires were pulling in, as well as a good deal of additional information
that was not included in the surveys.
Secondly, the Bureau survey staff were aware that action recommenda-
tions are inevitably influenced by an estimate of the effect of other
variables not available in the survey data. They recognized the extensive
tact-gathering process in which CEEB study staff had been engaged and the
information they had gained on such matters as issue salience and polit-
ical acceptability. They realized that CEEB was bringing additional con-
siderations to their review of the questionnaire results and filtering
the information through their own knowledgeability. They were willing
to accept both the substance and the legttimacy of the CEEB role.
At this point there was one issue on which the CEEB recommendation
seemed to contradict the data: loan cancellation for teachers. The col-
leges wanted to retain cancellation. They said it did not make loan col-
lection more difficult, that their experience with it was satisfactory,
and it should not be eliminated. Nevertheless, the CEEB took the position
that it should not be extended to the GIP and might well be eliminated
from the NDSLP.
The CEEB stance was based on factors other than the opinions of the
colleges. The costs of carcellation were increasing, Other critical
prctessionsl fields, such as law enforcement and social work, were
expressing a desire for loan cancellation--with considerable justice.
Moreover, staff of the Office of Education in Washington and the regional
offices were spending an extravagant amount of time determining eligibility.
Even the questionnail:e itself could supply some support for the
CEEB position. Thus, only 13 per cent of the schools said that cancel-
lation had definitely increased the number of students going into
47.
teaching, and another 42 per cent thought it had "probably" increased
the supply of teachers. Based on this kind of "opinion" evidence,
elimination of the cancellation provision was not definitely contra-
indicated. Nash himself agreed with the CEEB position on ending can-
cellation. Despite the colleges' interest in retention, he felt it
fully justified on other grounds, e.g., the costs, administrative bur-
den, unfairness to other low-paid occupations.
At the close of the meeting, the staff allocated each of the 24
recommendations or areas for recommendation to a member of the group to
work on. The Nashes, as part of the team, were assigned to write up .
the recommendations dealing with cancellation of loans fe'r teachers,
making loans profitable for banks, need for continuation of the NDsLp,
inefficiency of income tax credits for tuition payments, plus six
technical matters on which there was little strong staff opinion and
for which the questionnaire responses were tc% be consulted.*
An Advisory Committee meeting was coming up on October 26, 1967.
It was scheduled to discuss findings and recommendations particularly
on the Guaranteed Loan portion of the study. A digest was prepared of
the recommendations and supporting material that the staff members had
written, and mailed to committee members on October 20. (See Appendix B
for the recommendations in the October 20 draft.)
*These were: maximum amount of borrowing for each student, length ofgrace period, need for co-signers for minors, whether the GuaranteedLoan should be given to the student or to the college, disbursementof loan funds once or twice a year, and whether the bank or the collegeshould supply loan application forms.
148
The October 20 materials mailed to Advisory Committee members came
in three sections. The first section was subtitled, "Federalism and
Creative Federalism," and posed the question of whether the Guaranteed
Loan Program should be a "Federal partnership, i.e., creative federal-
ism or a Federal bureaucratic operation." The paper opted for "crea-
tive federalism" with 50 strong state guarantee agencies. This was a
key concern of Kirkpatrick's, and was unrelated to the survey data.
The second section made a strong case for the separation of loans
of necessity from loans of accommodation. It cited support for a
financial need criterion for Guaranteed Loans from the colleges and
u:,iversities and lending institutions in the study, and from the Ameri-
ctn Council on Education, American Bankers Association, state guarantee
agencies, and United Student Aid Fund. A strong recommendation was
made that colleges should be responsible for determining students'
financial need and recommending to the lending institution the amount
of the loan. A third section listed 15 "other problems and findings."
The Advisory Committee discussed the statements. The meeting was
lively. Members spoke from a variety of viewpoints -- recounting their
on experiences in different states, different institutions, different
positions.
But for at least one meuber of the group, there was a sense of dis-
quiet about the function of the meeting. John F. Morse, the influential
director of the Commission on Federal Relations of the American Council
on Education, stated that the draft before the committee was more a
position paper than the result of a study based on factual analysis.*
*College Entrance Examination Board, "Highlights, Advisory CommitteeMeeting, October 26, 1967," mimeographed, p. 2.
149.
Although it spoke of evidence, little was given for the policy positions
being taken. He cited the statement on the maximum borrowing allowed a
student per year. The CEEB working paper stated: "While there exists
a certain amount of differing opinion about these limitations (i.e.,
present legislative maximums on borrowing), the evidence seems to sup-
port them as sound guidelines." What evidence? This was an important
matter, deserving of serious study, but he saw no relevant research
results.
Kirkpatrick responded, according to the CEEB minutes of the meet-
ing, that "since the study was being made so early in the life of the
Guaranteed Loan program, the views presented in the document before
the committee necessarily had to be based on opinions and judgments
growing out of the various conferences, interviews, and questionnaire
responses expressed by the several participants in this loan program."**
George Nash, who had been sitting at the meeting with a pile of
tables in front of him, uncomfortable that the survey data were being
ignored, was buoyed by Morse's statement. He saw it as a vindication
of the position he had been advocating--greater reliance on the ques-
tionnaire data. He has since said that Morse's comment, and the later
reactions to it, marked a turning point in the CEEB's manifest use of
the questionnaire data.
*CEEB, "Other Problems and Findings," working paper for OctoberAdvisory Committee.
**CEEB, "Highlights," stp... cit. This statement reflects a variation ofthe theme of "timing" as a factor in research utilization. The stageof the program at which research is begun can place limits on the typeand relevance of the research that is undertaken.
50.
But what Morse V&A objecting to here was not so much that the
questionnaire data were being bypassed as that the data themselves were
based on opinions, and not necessarily opinions of the most qualified
observers. For example, the "evidence" for maximums on borrowing
reported in the CEEB working paper did come from the responses of banks
and educational institutions that present limits were sound. Morse was say-
ing that they needed to know more than this about the effects of borrow-
ing.
The attention directed to research data, nevertheless, was suppor-
tive of Bureau efforts to keep the survey responses in view. At one
point in the meeting, Kirkpatrick mentioned a facet of banks' opinions
which he had learned through personal conferences, but which was at
variance with the questionnaire responses. Nash spoke up and cited the
data. Members of the Advisory Committee evinced interest in his state-
ment and in hearing more about the questionnaire results. He took a
few minutes to bring some of the findings on the GLP before the group.
While there was considerable diversity of Advisory Committee
opinion, and questions about the data, the meeting ended in substantial
agreement with most of Kirkpatrick's recommendations. The next draft
of study recommendation; which was mailed to Advisory Committee members
on December 4, is very close to the statement of October 20. (See
Appendix B, Coln= 3.) Almost the only change is the sharpening of
implicit positions. No additions of any significance were made.
Mr. Morse himself felt bound to resign from the Advisory Committee.
In his position at the American Council on Education, he worked with a
carefully selected commission to formulate policy positions on
51.
educational issues. If the Advisory Committee, rather than advising on
research, was also setting policy, he ran into potential conflicts.
So--amicably--he withdrew.
One consequence of the meeting was that because of discussion on
the subject, CEEB paid further attention to the maximums on borrowing
and the concept of reliance on student borrowing to finance higher edu-
catZon. In the final report, a recommendation would be made that "an
economic, educational, and social analysis of the impact of borrowing
be undertaken . . . to determne what might be considered reasonable
maximum indebtedness . . ."
In the days following the Advisory Committee meeting, CEEB study
staff met frequently to plan, draft, and revise sections of the final
report. Bureau staff sometimes joined them. The January deadline was
approaching, and there were still data to analyze and opinions to recon-
cile. Because he wanted more interpretation of the questionnaires,
Kirkpatrick asked the Nashes to produce a written report on the surveys.
The Nashes had not intended to produce a separate report, but were will-
ing to satisfy the request.
Thus in November 1967 they produced "A Report of the Opinions and
Practices of College Student Financial Aid Administrators at Institutions
of Higher Education, Health Professions Schools and Nursing Schools on
the Federal Student Loan Programs." Included for each group were the
tabulations, cross-tabulations, and interpretation of the questionnaire
responses. One of the more interesting features was an analysis of the
correlates of satisfaction with the loan programs. Obviously the timing
of these reports made them almost unusable in the preparation of the
52.
final report, which was being written simultaneously. At this point
they were for the record rather than for planning or decision making.
A second Advisory Committee meeting in December reviewed the data,
position statements, and recommendations of the total study. It was a
large group, and although diverse and important statements were made,
there were few significant changes made in the draft report. Perhaps
the clearest effect of the meeting concerned the recommendation on end-
ing the interest subsidy on Guaranteed Loans during the repayment
period. Lack of evidence on the effects of interest subsidy and lack
of consensus among the advisors led to a middle-of-the-road position:
the final report included a discussion of the pros and cons but recom-
mended only that eliminating the subsidy be considered in the future.
There were practically no changes in the recommendations after the
December 11 meeting.
In a hectic year-end marathon, CEEB almost made the December 31
deadline for the report. A pre-publication draft appeared on January 12,
1968, and the final version, almost unchanged, was transmitted to the
Office of Education in late January.
Report of the Study
The report was a mimeographed document, 1-1/4 inches thick, 230
pages long, bound in hard plastic covers. It contained 11 chapters and
9 appendices. In February, the Rashes completed the pilot study of
student borrowers, and the report of these data was added as Chapter
XII. All the questionnaires were reproduced in the appendices, and
total answers for each question were shown. A few basic cross-
53.
tabulations also appeared, e.g., type of bank, type of health profes-
sions school.
Chapter I was a statement of the purpose of the study. The second
chapter reviewed the dollar amounts of student aid. The third chapter
was the key section. It summarized all the recommendations of the study
and indicated some highlights of the supporting evidence. The following
chapters dealt with each loan program separately in detail--National
Defense, Health Professions, Nursing, Cuban, and Guaranteed Loan Pro-
grams (including Vocational Student Loans). Here pros and cons, evidence
and testimony, were discussed. The last three chapters dealt with the
concept of a revolving fund for financing federal loans, uniformity of
provisions, and central administration.
Chapter III, the summary of the recommendations, was the heart of
the report and the section most likely to be read. It contained 14
recommendations. (Appendix C of this paper lists all the recommendations.)
It is sometimes suggested that a reason for non-use of research
results is that the report stops short at the point of analysis and
fails to draw explicit recommendations for action. Clearly this was not
the case here. The whole report was organized around the recommenda-
tions. Other considerations (description, analysis) were subordinated
to the presentation of clear and specific recommendations.
Table I,shows the types of evidence cited for the key recommenda-
tions in the study report. The questionnaires of the Bureau survey
clearly-lead in mentions. Since they appear to have had only a support-
ing role in the story so far, their primacy is interesting. Perhaps the
nature of quantitative data makes them more available and easier to use
Recommendation
TABLE 1
TYPES OF EVIDENCE MENTIONED IN STUDY REPORTFOR MAJOR RECOMMENDATIONS
Frequency of Source Cited forEach Recommendation
Ques- Govern-tian- Inter- ment Advisorynaires views statistics Committee Other
1. Financial need cri-terion for GSLP
2. Colleges should deter-mine who receives GSL
3. Banks should have higherrate of return on GSL
4. Grace period should beshortened
5. States should establishcentral service divi-sion or central poolof credit
6. Separate administrationof loans for non needy
7. Consider ending GSLinterest subsidy
8. Combine loan programsinto two
9. Centralize loan programadministration
10. Hold NDSLP at present
4 3 1
4 1
4 2
1
1 1 1
1 1
1 1
levels of funding 6 4
11. End loan foregivenessfor teachers 3 7 4
12. End loan forgivenessfor nurses 2
Total 26 13 14
1
1 1
1 1
1
7 2
55.
than qualitative materials. Numbers provide information in highly con-
densed form, making them convenient for a pithy report. Furthermore,
because the data derive from large numbers of respondents, they lend an
aura of certainty, completeness of coverage, scientific respectability,
and legitimacy. The frequency of mention does not contradict our sense
that the choice of which questionnaire data to use was influenced by
their concordance with predilections derived from experience and field
work.
The next column of the table, "Interviews," is shorthand for the
CEEB data collection through conferences with officials, meetings with
representatives of relevant institutions, and interviews with state
guarantee agencies. The interviews were obviously important in two key
recommendations, both of which were highly controversialoind they were
mentioned once under three others. "Government statistics," the third
column, shows a relatively high frequency of citation. This column
refers to data prepared largely by the Office of Education on such sub-
jects as dollar amounts of aid and family income of students partici-
pating in the loan programs. The final column, "Advisory Committee,"
refers to specific mention of the committee in the discussion of the
recommendation. The seven mentions here are spread over seven recom-
mendations.
However, the mention of a source does not necessarily mean that
the source supports the recommendation. In the case of the recommenda-
tion to end loan forgiveness for nurses, for example, there are two
mentions of questionnaires. One directly opposes ending forgiveness
and the other leans strongly in the same direction.
56.
Therefore, it may be well at this point to look at the correspon-
dence between the report recommendations and the questionnaire survey
data. While we recognize that the survey was only part or the research
done in the study, and probably not the most influential, it is the only
part that is accessible. As noted earlier, the conferences and most
interviews went unrecorded. As we continue our investigation of the
utilization of the study, it will be important to know how firmly the
recommendations rest on evidence--and the survey evidence alone is sys-
tematically presented. Further, as we will see, questions will be
raised ty policy-makers about the basis for study recommendations. Since
the survey data are the chief support offered for the recommendations,
the users of the study in the Office of Education and in the Congress
will take them seriously. Fbr all of these reasons, then, we turn to an
analysis of the fit between the questionnaire data and the recommenda-
tions.
The relation of the recommendations to the questionnaire data. Mast
of the recommendations were unconnected with the survey data. (See
Appendix C for a classification of recommendations and survey support.)
Many dealt either with administrative matters (which were relatively
minor) or were noncontroversial. We will limit our attention to those
recommendations that (1) required legislative action, and (2) evoked
controversy. In most of these cases, there are survey data available.
The reasons for eliminating non-legislative issues are twofold.
First, almost by definition they tend to involve routine administrative
issues. Secondly, in these cases, the source of information was likely
to be the administrators of the loan programs themselves. That is,
57.
the Office of Education (and to a lesser extent the Public Health Ser-
vice) were not only the clients of the study; they were also the pur-
veyors of much of the evidence and opinion on which the administrative
recommendations were based. It would be almost impossible to say to
what extent implementation of a procedure meant that the Office of
Education was using the CEEB study recommendation. It is equally likely
that CEEB is "using" Office of Education information.*
We look only at recommendations that were likely to evoke contro-
versy on the Hill, because acceptance of noncontroversial recommenda-
tions can hardly be ascribed to anyone's influence.
Twelve recommendations meet both the "legislation" and "contro-
versy" criteria, and we will focus on these:
Three are supported by the survey:
(1) Financial need criterion for GSL
(2) Colleges' determination of receipt of GSL
(3) Higher rate of return to banks on GSL
Two receive some support from the survey:
(4) Shortening of the grace period
(5) States' establishment of central service division orcentral pool of credit for problem borrowers
*Confirmation of this po4alt comes from the Office of Education's officialcomments. In most cases, they stated, they were already implementing therecommendations that they agreed with, and as the resident experts, theywere not swayed by those they disagreed with. U.S. Congress, House ofRepresentatives, Special Subcommittee on Education, Committee on Educa-tion and Labor. "Summary of Recommendations in College Entrance Examina-tion Board Study with Comments of Office of Education," Higher EducationAmendments of 1968: Confidential Subcommittee Print No. 2, 90th Cong.,2nd seas., 1968.
58-
On three recommendations, the survey did not provide data:
(6) Separate administration of loans of accommodation fornon-needy families
(7) Consideration of ending GSL interest subsidy
(8) Combining six loan programs into two
Four were contradicted by at least some survey data:
(9) Centralization of loan program administration
(10) =LP appropriation at present level
(11) End of loan forgiveness for teachers
(12) End of loan forgiveness for nurses
Let us now look in more detail at the relation of the survey to
these recommendations.
(1) Financial need criterion for GSL, and (2) Colleges' determina-
tion of receipt of GSL. Financial aid officers in the schools were not
directly asked for their opinion on imposition of a needs test. But
they were asked if they thought that. the school should specify the maxi-
mum amount to be loaned under the Guaranteed Loan Program. Three-
quarters said yes, when the atudent zas financial need (48 per cent,
definitely; 27 per centyes, probably), aid 63 per cent said the school
should specify the amount when the student does not have need (43 per
cent, definitely; 20 per cent, probably). Sixty -five per cent were
already recommending to the banks the amount to be borrowed in most or
some cases. These findings were interpreted not only as support for a
strong role for the colleges in determining who gets guaranteed loans,
but also as implicit support for consideration of the financial aid
officer's specialtydetermination of need.
59.
Ninety-five per cent of the lending institutions believed that
students' financial need should be taken into account in deciding
whether to award a Guaranteed Loan. Eighty-three per cent wanted
colleges' recommendations on the amount of loan. Twenty -five per cent were
already in regular contact with colleges about loan applications, and
84 per cent of these accepted the colleges' recommendations on the
amount of loan in most cases.
However, "financial need" was not defined in the questionnaire.
Mr. Bayer of the Insured Loans Branch in the Office of Education sug-
gests that what banks mean by taking financial need into account is that
the loar is consistent with the expected expense; you don't lend $3,000
to meet $2,000 of college expenses. C. E. Deakins, then Chief of the
Insured Loan Branch, had pointed this out to Kirkpatrick in 1967 when
the questionnaire to banks was being drafted. "This question (Does
your institution take the student's financial need into consideration
when making loans?) needs further clarification. There is ,zonfusion
between our definition of 'educational costs or need' and the CSS
[College Scholarship Service of the CEEB) definition of need."*
(3) Higher return to banks. Banks' questionnaire supported this
position. Only 6 per cent of the responding lenders found the existing
6 per cent rate profitable. Thirty-three per cent said it was break-
even, and 61 per cent said it was a loss rate. Since the low rate of
participation of lending institutions in the program and the small
nlmber of loans made even by participating banks were already known,
*Letter from Deakins to Kirkpatrick, June 22, 1967.
6o.
these data confirmed that it was the return rate that banks found
unattractive.
(4) Shortening the grace period for all loan programs. Colleges
weren't asked for their views on the question. Banks were asked if
they agreed or disagreed with the statement, "The present 10- month
period allowed after graduation before the student must begin to make
repayment on the Guaranteed Loan is not excessive." Fifty-two per cent
of all lending institutions agreed that it was not excessive. But of
the large commercial bank;, who were as a class the most active lenders,
only 39 per cent agreed.
The decision to recommend a grace period of four months, and to
have it apply to all loan programs, was a tenuous elaboration from these
data.
(5) states' establishment of central service division or central
pool of credit for problem borrowers. No one was queried about tne
setting up of a central service .'.:vision or 4 central pool of credit.
What the survey did was show that there were students reported to have
problems obtaining a guaranteed loan. Leading institutions said that
they generally limited loans to borrowers in their "marketing area,"
and many of them gave preference to present customers (27 per cent said
without exception, 4o per cent said yes, but we make some exceptions).
A few banks owned that some students have considerable trouble getting
guaranteed loans: freshmen, ccording to 11 per cent; students from
rural areas, according to 9 per cent; students from low-income families,
according to 3 per cent.
61.
Educational institutions more often reported that students had
trouble obtaining guaranteed loans: 45 per cent said that students
unknown at the bank have considerable trouble, 23 per cent said out-of-
state students, 15 per cent said students from rural areas, 13 per cent
said freshmen, 13 per cent said students from low-income families,
10 per cent said racial minority group students. Some readers of the
data wondered whether these responses reflected the state of the
financial aid officers' records or of their prejudices.
(6) Separate administration of loans of accommodation for non-
needy families. This recommendation was the outgrowth of the establish-
ment of a financial needs test for the GSL. Non-needy families would
no longer be eligible. Therefore, if the Congress wanted to be good
guys and help families who didn't need loans, they should set up a
separate agency and system, without charging the costs against educa-
tion. No data, beyond those supporting the financial need criterion
for GLP, support the recommendation.
(7) Consideration of ending interest subsidy in the GLP during
the repayment period. No one was asked.
(8) Combining six loan programs into two: the Guaranteed Loan
Programs and all others combined. Educational institutions weren't at all
prepared to forego NDSLPI HPSLP, and NSLP and rely solely on the Guaran-
teed Loan Program, so it was not feasible to combine all the programs
into one. But nobody was asked about combining them at all.
(9) Centralization of loan program administration. This recom-
mendation in essence meant moving the Health Professions and Nursing
Loan Programs to the Office of Education. The health professions and
62.
nursing schools weren't queried about this possibility. What they were
asked was their satisfaction with the Public Health Service. They were
very satisfied. The recommendation for consolidation was based largely
on notions of efficiency.
(10) NDSLP appropriation at present level. This recommendation
ran counter to the schools' expressed desire for more NDSLP funds.
Forty-two per cent stated that the amount of NDSLP funds was inadequate;
89 per cent did not plan to decrease the size of their NDSLP loan
request because of the availability of the Guaranteed Loan Program.
The recommendation, however, was responsive to the Office of Edu-
cation guideline about minimizing direct federal loans and maximizing
loans from private sources. The wording of the CEEB recommendation
and the discussion of it show that the study staff felt that they were
being bold in defying the implicit injunction to reduce or phase out
the NDSLP. To the extent that they urged the maintenance of NDSLP at
existing levels, rather than reduction, the recommendation used the
survey data. But when the recommendation was read and discussed in
1968, the early history had grown dim ane the unintended meaning that
came through was: Don't increase NDSLP.
('1) End of loan forgiveness for teachers. Educational institu-
tions favored the forgiveness feature. In response to a question on
the future of cancellation in the NDSLP,
67 per cent of colleges said there should be no change22 per cent of colleges said eliminate all cancellation11 per cent said extend cancellation.
63.
Asked whether cancellation made collection of loans more difficult,
4 per cent said yes, definitely11 per cent said yes, probably85 per cent said no.
Asked whether cancellation increased the number of students at the
institution who went into teaching,
13 per cent of colleges said yes, definitely42 per cent said yes, probably45 per cent said no.
The respondents to the college questionnaires were financial aid
officers, and some interested readers of the report questioned the aid
officers' knowledge of the facts; deans of education, for example,
might have given different responses.
The "hardest" research data came from the pilot study of student
borrowers. Questionnaires were mailed to 285 graduates of the class of
1965, from schools in the Metropolitan New York area, who were paying
off their NDSLP loans; 109 questionnaires were returned. Of these,
`7 per cent of the borrowers expected that part of their loan would be
cancelled because they were or will be teaching. This represents
62 borrowers. Of the 62, 91 per cent said that cancellation
had not influenced their decision to go into teaching. This finding
was the strongest support for the recommendation, since it showed that
cancellation had little pull. But the figures were very small and
drew only from New York City graduates. It was hard to lean on them.
And there were even those who commented that increasing the teacher
supply by 9 per cent was no mean feat.
The interesting thing, however, is that the results of the pilot
study were not available at the time that the recommendations were
614.
formulated, discussed, and accepted. The results came in in February,
after the report was completed and submitted. They were sent to
Washington as an appendix to the final report.
(12) End of loan forgiveness for nurses. Nursing schools favored
forgiveness.
67 per cent said there should be no change24 per cent said increase the amount of cancellation9 per cent said eliminate all cancellation
Asked whether cancellation had increased the number of students who
went into nursing practice, 4,j per cent said yes.
Thus, for the twelve recoNnendations, there was wide variation in
the degree of correspondence between data and recommendation. Even at
best, however, the data were not seen as conclusive. In a later sec-
tion we will consider whether strong research support increased the
power of a recommendation. But our inquiry will be limited by the fact
that the strongest research support for a recommendation present in
this study was open to criticism and debate.
Chronology -- Phase II
The following table summarizes the events of April 1967 to
January-February 1968.
Office of Education
1967
April-May - -Advises on
survey questionnaires.
June--Receives pre-
liminary question-
naire results.
-Discussions on mer-
ger of loan program
administration; deci-
sion is made not to
merge.
Aa.--Begins planning
legislative proposals
for 1968.
-HEW task force draws
up Higher Education
Amendments of 1968.
Oct.--Attends Advisory
Committee meeting.
Dec.--Attends Advisory
Committee meeting.
Phase II - Conduct of the Study
Bureau of Applied Social
College Entrance Examination Board
Research
April- -Participates in development
of questionnaires.
June - -Receives preliminary ques-
tionnaire results.
-Holds interviews with federal
officials, representatives of
agencies, and interest groups.
May -Aug. - -Interviews with financial
aid officers, bankers, et al.
Aug.-Oct. - -State Conferences.with
financial aid officers, bankers,
et al.
Oct . -Jan. - -Develops recommendations
Oct.--Advisory Committee meets on
GLP.
Dec. - -Advisory Committee meeting.
1968
Jan.-48st minute changes
Jan.--Submits study report to
in Higher Education
Office of Education.
Amendments.
April- -Develops survey
questionnaires.
ntSends questionnaire
out to colleges.
June - -Sends out pre-
liminary results of
colleges' questionnaire.
July--Sends questionnaires
to health professions
schools.
Ala.Questionnaires to
vocational educational
institutions.
-Questionnaires to
lending institutions.
-Questionnaires to
nursing schools.
.Oct.-Jan.--Helps CLLR to
develop recommendations.
Oct.--Attends Advisory
Committee meeting.
Nov.--Prepares report on
Guaranteed Loan Program.
Dec.Attends Advisory
Committee meeting.
-Report on NDSLP and
other loan programs
Feb.--Prepares report on
study of student borrowers.
66.
Chapter III
DECISIONS ARE MADE
Meanwhile at the Office of Education
While the study was in progress, four related activities
were going on in the Office of Education. First, staff of the
Division of Student Financial Aid reviewed the experience of the
College Work-Study and Educational Opportunity Grant programs.
Second, staff were keeping in close contact with CEEB. Third,
representatives participated in Intradepartmental discussions
within HEW that considered consolidating the administration of
all loan programs, an issue that the study staff was also
pondering. Finally, beginning in August, the legislative planning
cycle began and the Division of Student Financial Aid started
drawing up proposals for 1968 legislation. OE specifications
went to a departmental task force that framed the student aid
section of the Administrations' higher education bill.
(1) Review of College Work-Study and Educational Opportunity
Grant Programs. The Division of Student Financial Aid reviewed
experience and data on these financial aid programs in-house,
with an intent similar to, although on a much more restricted
scale than, the CEEB study of loan programs. CEEB had not been
charged with any responsibility to assess these programs. How-
ever, as a service to OE, the Bureau included in the question.;
naires a few questions on schools' participation and satisfaction.
67.
OE staff drew on these data as well as their knowledge of
operations, correspondence and complaints, and statistics.
(2) Close touch with CEEB. James Moore, director of
the Division of Student Financial Aid, shepherded the CEEB
study from its earliest beginnings. He and his staff were in
constant contact with CEEB during its course, reviewing the
questionnaires, writing an explanatory letter to colleges to
urge their participation in the survey, tabulating OE data on
loans, conferring on the issues. OE people attended both Ad-
visory Committee meetings on the study.
In June, they received from the Bureau the basic results
of the first 700 questionnaires returned by colleges. (There
was almost no change in the distribution of responses when the
final number of 1700 college responses was tabulated. As Nash
stated, "After one month they knew the facts and could adjust
to reality.") It was particularly important they keep abreast
of the study in progress because legislation for 1968 would
have to be drafted before the final CEEB report was submitted.
In the legislative planning cycle, work starts on new
proposals in the sumMer so that the Presidential budget can be
ready by. January and new legislation introduced early in the
session. At the time that the study of loan programs was
first conceived in spring 1966, it was expected that the timing
would be appropriate and that the study findings would be ready
by the time legislation was being develciped. However, because
68.
of the delay in late 1966 in deciding on the focus of the study
and its funding, the due date for the study was pushed back to
January 1, 1968. OE staff proceeded with legislative proposals
without the full CEEB report, although they knew much of the
content before it was finished.
(3) Intradepartmental discussions on consolidation.
Secretary Gardner was deeply concerned with streamlining the
biiramshackle department of HEW. In his attempts to bring
order he looked into the-possibility of consolidating the
administration of all the federal loan programs. Represent-
atives of the affected agencies and the Secretary's office
met and considered the pros and cons in early-1967. It was
evident by the summer of 1967 that there was too much re-
sistance to force the OE and PHS loan programs together. PHS,
which was the likely loser, was no happier than any bureau-
cracy at the idea of losing personnel and budget from a program
it believed it was administering well and with special expertise
in health-profession education.* Pressing the point might jeopard-
ize larger schemes for reorganization in PBS.
Therefore, a more modest assignment was made. Secretary
Gardner appointed a task force to consolidate three of the OE
student aid programs,into a.single enactment--NDSLP, College
Work-Study, and Educational Opportunity Grants--and to bring
greater consistency of administration to the others. Samuel
Halperin, HEW Deputy Assistant Secretary for Legislation, headed
*PHS saw the health professior1S loans as serving different purposesand meeting different needs from other loan programs; they werepart of an integrated system of financial assistance to healthprofession schools (which were usually largely separate from therest of the university); consolidation would increase work andproblems, and might well jeopardize the purposes of the healthprofessions loan programs. (I thank Alice Swift, Student Loanand Scholarship Branch, Division of Health Manpower EducationalServices. for clarifyjne. t1ic PHS perspective.)
69.
the task force. Members came from the Office of Education.. Public
Health Service, General Counsel's office, Comptroller's office,
and other parts of the Secretary's office. The task force was
to draw up key provisions for the higher education legislation
of 1968.
(4) Legislative planning. OE began developing
specifications for loan program legislation in August and
September 1967. Since Secretary Gardner's new task force was
now charged with responsibility for drawing up the financial
aid title of the Higher Education Amendments of 1968, OE took
its proposals to the task force through its representatives on
the group.
OE proposals on student aid represented established
positions, in most cases not related to the issues that were
engaging the attention of the CEEB. There is one case where
it appeared that the CEEB study, along with some prodding from
other sources, influenced OE to bring in new provisions. The
issue was inconsistencies among different loan programs. OE
proposals reflected an effort to get uniform provisions in the
various programs on such matters as deferrals of repayment
during military, Peace Corps, and VISTA service,and minimum
amounts of repayment. (Senator Javits of the Senate Sub-
committee on Education, who had been interested in ensuring
greater consistency for some time, found that these efforts
were not thoroughgoing enough. When both OE and PHS loan
70.
bills reached the Senate Subcommittee, he succeeded in amending
them into further reconciliation.)
On the issue of loan cancellation to teachers, the t)ffice
of Education was willing to abandon the provision. Thay felt
that in the individual case a few hundred dollars of forgive-
ness was hardly likely to affect a person's long-term career
decision. The administrative difficulties -- and all the
correspondence involved in determining whether an individual
qualified as a full-time teacher -- were a. nuisance. Mbre-
over, the costs of cancellation were going up, reaching
$18 million in fiscal 1969, and projected at $20..million
for 1970.
The task force worked through the fall and winter of
1967. Members of the task force, other than the Office of
Education representatives, say that they knew about the CEEB
study, and after its'submission to OE in January, they were
familiar with its main recommendations. But it had no effect
on their legislative proposals except insofar as the OE pro-
posals might have incorporated the CEEB recommendations. As
one member of the task force stated, "1 can't point to
single thing attributable to the Board study. Next year or
the year after, the weight of things will begin to be felt,
and the report may be a factor."*
*As this statement suggests, the appropriate time interval is diffi-cult to determine in studying the utilization of research. Some re-search that is not acted upon early, may be put to use after the'student of utilization has left the scene. Research that appearsAmused may slowly be absorbed into the thinking of elites and pub-lics, leading over-time to significant shifts in practice and policy.
71.
Some members of the task force, particularly its chairman,
Dr. Halperin, were disappointed in the study when it arrived.
They had hoped for more rigorous data on two of the controversial
policy issues -- increase in return to banks and cancellation of
loans for teaching. The report in both cases reported opinions.
It did not show bank yields or survey the banks' alternatives.
It did not give information on the actual effects of loan
cancellation on recruitment into teaching. Those members who
agreed with the CEEB recommendations on both counts found the
evidence too thin to briig them much support.
The Office of the Secretary of HEW did not want to reverse
the department's traditional position of supporting loan for-
giveness, despite OE's desertion from the fold. The department
had held that cancellation was a good thing for a long period
of time, and it was awkward to do a complete turnabout. Further-
more, there was no sense in the department's getting into the
middle of what was surely going to be a donnybrook between the
House and the Senate. The House, led by Mrs. Green and Mr. Quie,
was out to end forgiveness, while the Senate, under the leader-
ship or Senator Morse, was looking for more and more categories
72.
of people to forgive.
This is an illustration of the theme of the "plowed field."
Cancellation of loans for teaching had engaged Congressional attention
almost from the beginning of NDSLP in 1958. The House leadership
had long since become convinced of the inefficiency of forgiveness
and the ensuing waste of public funds. The Senate subcommittee, on
the other hand, saw loan cancellation as an opening wedge in the cam-
paign for free higher education for all. It was adamant against
withdrawing financial help that had already been won.
The CEEB report was reviewed in the task force and in the
Secretary's office, and the findings on the effects of forgiveness
were deemed inconclusive. The decision was made that the depart-
ment would no longer press for forgiveness, a decision in itself
of some consequence, and one which the study helped to justify.
But neither would the department press for ending it. The new
legislation to be introduced into the Ninetieth Congress did not
mention the subject.
The Office of Education had an opportunity to go on record
directly on all of the CEEB recom.14ndations. The House Special
Subcommittee on Education, which as we shall see received the re-
port on February 16, asked Commissioner Howe for the CE position on
each recommendation. Mr. Howe's reply took exception to a number
of the key recommendations of the study. Although we must jump
ahead in the time sequence of the story--Mr. Howe's statement was
dated March 15--we present the OE statement here as evidence of tne
reaction of the major client to the study.
73.
The Office of Education Goes on Record ci the CEEB Recommendations
On March 7, 1968, Mrs. Grceu wrote to Commissioner Howe
asking for the Office of Education position on the recommend-
ations contained in the "Study of Federal Student Loan Programs"
conducted for the Department by the College Entrance Examination
Board. On March 15, Mr. Howe replied. Here we have the con-
sidered position of the department. The OE position paper,
before release, was carefully reviewed by the HEW legislative
office and other staff of the Secretary's office.
Of the twelve CUB Tt-Idy recommendations of
greatest salience, OF ag2,Jed with three, disagreed with five,
said "not now" on three others, and did not comment on the one
related to the Public Health Service's loan program.
Agreement was recorded with the following recommendations:
1. A higher rettrn to banks. Provisions to increase
bank return were included in the Administration bill
2. Shortening the grace period. OE stated its agree-
ment, but this provision had not been included in the
Administration bill.
3. Consideration of the removal of the GLP interest sub-
sidy. The Office of Education agreed to "give con-
sideration to the matter." Both the recommendation and
the OE concurrence were phrased in future tense. The
Administration bill did not remove the subsidy.
74.
The Office of Education disagreed with these recommendations
of the CEEB report:
4. A financial need criterion for the Guaranteed Loan
Program. The purpose of the program, Commissioner
Howe said, is specifically to provide assistance to
middle income families who are not eligible for loans
through the college-based programs.
5. Separate administration of loans of accomodation to the
non-needy families. The Office of Education disagreed
with some asperity. GLP should serve all families.
The cost of obtaining postsecondary education
continues to increase each year. The financialpressures now bear heavily not only on the lowmiddle income family, but also on middle andupper middle income families who only a fewyears ago were capable of paying for theirchildren's education. We believe the insuredloan program was established to meet this need...Further, we see aittle point in a further pro-liferating of student loan insurance activitiesamong other Federal agen6ies.
6. Having colleges and universities assume responsibility
for determining who should receive Guaranteed Loans
and recommending the amounts. The Office of Education
concurred "in the spirit" that colleges should have
some responsibility, but disagreed with the substance.
Aatual negotiations, said OE, "should remain between
the student and the lender." Colleges have the oppor-
tunity under current statute to provide information and
advice.
75.
7. Encouraging states to set up a central service division
or central pool of credit for students having difficulty
obtaining loans. The Office of Education stated that
where the idea had been tried, it had proved "very
ineffective."
8. Maintaining NDSLP appropriations at a level not below
the 1968 level.
If the implication is that the direct annualappropriations for the NDSLP should be held atthe 1968 level, we do not concur in thisrecommendation.
On three further recommendations, the Office of Education
said that their time had not yet come.
9.Combining the six loan programs into two. The Office of
Education said that "it is not deemed feasible to
consolidate the PHS and OE programs, at this time."
10. Centralization of all loan program administration. The
Office of Education stated that such a recommendation
is being explored by the Department.
11. Ending loan cancellation for teachers. The Office of
Education withheld judgment for the time being. It
called the CEEB study "inconclusive" on the effective-
ness of cancellation as a means of recruiting teachers.
Further study might be done, said the statement, although
at this point the educational community is sharply di-
vided. The 1968 Administration bill left the forgive-
ness provision intact.
76.
On the final recommendation, ending loan cancellation for
nurses, the Office of Education did not comment. That was the
business of the Public Health Service which administers the
nursing loan program. The Public Health. Service itself was
opposed to ending loan cancellation for students who entered
nursing.
On those issues where OE disagreed with the CEEB recom-
mendations, it is evident that both administrative and ideo-
logical considerations were involved. Thus, administrative
ineffectiveness was grounds for dissent in some cases: a
central credit pool does not work, separate administration
of loans of necessity and loans of accomodation would un-
necessarily proliferate loan activity among federal agencies.
Ideological grounds predominate in objections to the main-
tenance of the current level of VIDSLP appropriations and the
use of a financial need criterion. OE invoked not only its
own sentiments but also the intent of Congress in opposing
financial need limitations and separate administration of
loans of accomodRtion.
The CEEB had also made other less controversial recom-
mendations. On these, the agreement score was =oh higher. The
Office of Ilducation concurred with the large majority of the
technical and procedural recommendations, such as simpli-
fying and standardizing reporting procedures, strenghtening
existing state agencies, earlier notification to colleges of
77.
funds available, adoption of a write-off procedure for defaulted
loans, standardizing provisions for deferment of repayment, etc.
Now let us go back to the chronological account and the
events occurring ct the time of the January submission of the
CEEB report to the Office If Education.
The Higher Education Amendments of 1968
When the CEEB's final report on the loan study arrived at
the Office of Education in late January, 1968 loan program legisla-
tion had already been drawn up. The loan title was part of the
Administration's omnibus education bill, the Higher Education
Amendments of 1968.
Nevertheless, there was some time and opportunity for the
study to influence affairs. Don Hirsch of the General Counsel's
Office in HEW recalls that changes were being made in the bill
right up until the day it was introduced into the House of Repre-
sentatives on February 5. In the last days, several decisions were
reconsidered in the office of the Secretary of HEW, both because of
the CEEB report and because of "internal factors" within the depart-
ment. The report was mentioned by the discussants and given some
significance. However, no changes were made in its direction.
Informants have been unwilling to name exact particulars, but they
stated that one decision made prior to the report's appearance,
whicl, was in agreement with the report, was changed in a direction
contrary to the report. In another case, a decision contra r- to
the report was looked at again but allowed to Rtand. Other in-
78.
putscommunications from many interest groups and concerns about the
political palatability of the legislation to the Congress--were
having an effect.*
The House Subcommittee Uses the Report
Staff of the House and Senate subcommittees on education were
informed about the CEEB study and received copies of the report
prior to its official release on February 16. The House Special
Subcommittee on Education was particularly interested. It found
that the CEEB report agreed with many of its own positions, such
as ending loan cancellation for teachers, increasing the rate
of return to banks, even with its old (now dormant) penchant for
consolidating the administration of the loan programs.
The information on the unprofitability of Guaranteed Loans
looked particularly useful. The Congress was loathe to increase
the cost of loans to students, particularly in an election year.
But without higher returns, banks would not make sufficient loan
funds available. The American Bankers Association had pressed for
higher returns, either through higher interest rates or through fees,
but had been able to marshal scanty evidence. The data that they
presented in the 1967 House hearings were based on a study of
only twenty banks.", The CEEB, study, by.ocllecting similar
*That the use of the study at the secretarial level was so modest doesnot gainsay the good faith of the department's "anticipated reliance"on the study. The study was instigated by the Secretary's office, a siz-able sum allotted for it, in the expectation that it could prove helpfulin upcoming decisions. By this time, reliance on the study was limitedby the timing delay, the "round shift" in the relative importance ofissues, and the over-riding necessity of ensuring Congressional sup-port for 1968 legislation.
Special Subcommittee on Education of the Committee on Education andLabor, House of Representatives, 90th Congress, 1st session, Hearingson Higher Education Amendments of 1967, Part I, p. 139.
79.
responses from about 600 landing institutions participating in
the GLP, lent the credence of numbers to the bankers' requests.
This would make it easier for the subcommittee to sell the
House on a higher return to banks, which it saw as essential for
survival of the Ouaranteed L^an Program.
The issue of consolidation also touched a sympathetic chord.
To prevent proliferation of the number of agencies administer-
ing student loan ;Tor-rams, a provision had been proposed in an
earlier Congress that no institution of higher education would
be eligible to participate in both the EDSLP and the Health
Professions Loan Program. The provision did not pass.* The
Special Subcommittee on Education had become reconciled to the
separation of OE and PHIS programs, particularly since it was ill
equipped to alter the situation. Not only is Congress rarely
eager to get embroiled in decisions on structure within the
executive department, but In this case, the issue was complic-
ated by the fact that in the House, the Health Professions and
Nursing Loan Programs do not fall within the jurisdiction of the
Committee on Education and Labor, as do the other loan programs.
The health loan programs are considered by the House Committee
on Interstate and Foreign Commerce.** Therefore, consolidation of
**That public health legislation should go through a committeedealing with interstate and foreign commerce is a historicalanomaly. The first public health bill, in the 18401s, dealtwith living conditions of seamen in the merchant fleet, andforeign commerce we the logical site for its consideration.For 120 years the tradition has prevailed.
HOwever, no student hvs ever been eli:jble to receive fundsunder NDSL and aPSL NOL.
80.
the programs is particularly difficult in the House, and probably
would have to originate on the Senate side, where different sub-
committees but the same committee (Labor and Public Welfare) have
jurisdiction. The Senate, however, had shown little interest in
consolidation.
The House Special Subcommittee had also recently undertaken
a questionnaire survey of colleges and universities to learn about
their experiences with student financial aid programs. In November
1966, the subcommittee mailed questionnaires to about 600 educational
institutions. Many of the questions were similar to those in the
CEEB study. For example: Do you believe teacher cancellation pro-
visions encourage students to become teachers who will remain to
the profession? From the 470 returned questionnaires, the House Sub-
committee concluded that OE staff were doing a good job in administer-
ing the programs, colleges favor the retention of teacher cancella-
tion, some students were having problems negotiating guaranteed
loans, etc.* The tenor of the results closely paralleled the larger
CEEB inquiry. The House subcommittee members saw their own study
confirmed, and because of the mutual reinforcement, they were en-
couraged to place stock in the CEEB results.
The Administration bill was introduced into the House (as
H.R. 15067) on February 5, 1968 by Representatives Carl Perkins
and Edith Green. In the hearings held by the House Special Sub-
committee on Education, the CEEB report had a prominent supporting
*House of Representatives, Report of the Special Subcommittee on Educa-tion, Study of the United States Office of Education, 89th Congress,2nd session, 1967, pp. 141-201, 471-584.
81.
role. It was accorded full measure of respect for its obvious.. right-
mindedness.
House hearings on the bill began on February 6, and went
on for 13 days, ending on March 8. On the first day of the
hearings, Congressmen Scheuer asked Education Commissioner
Howe whether any comprehensive survey had been made of the
suggested student loan, grant, and tax programs "to give us
some indication of how all the proposals impacted the individual
students, the family, the institution, and effects on society
in general . . ."* Mr. Howe replied that although nothing so
comprehensive had been done, the CEEB had examined various student
aid efforts and a report was in. Mr. Muirhead, associate com-
missioner for higher education, said in amplification that "hope-
fully within the next week or so"**the subcommittee would receive
the report. At the conclusion of the day's hearings Congressman
Esch asked, "In the light of the present consideration--and I know
the college board's study came in some time ago--is there any reason
why we can't have it immediately?" Mr. Muirhead answered, "No
reason at all. We have the study in its preliminary form now;
the delay is that it is t4ing printed."*"
Commissioner aowe sent copies of the report to Mrs. Edith
Green, chairman c.,r the House Special Subcommittee on Education,
*Hearings before the Special Subcommittee on Education of theCommittee on Education and Labor, House of Representatives, onR.R. 15067, Part 1, p. 48.
**Ibid.
**Ibid., P. 51.
82,
and to Senator Wayne Morse, chairman of the Senate Subcommittee on
Education, on February 16. The final paragraph of his accompany-
ing letter.
said:
While the Office of Education reserves the right to differwith any of the specific recommendations, we believe thatyou will find the study useful . . .
On March 7, John I. Kirkpatrick of the College Entrance
Examination Board, the director of the study, testified before the
House Subcommittee. (Most of the intervening hearings had dealt
with issues other than financial assistance; H. R. 15067 contained
12 titles of which student asssistance was only one.*) The first
question he was asked concerned the removal of the interest subsidy
during the payout period, a topic on which the study made no recom-
mendation. Mr. Kirkpatrick explained that there wasn't a sufficiently
strong case to warrant recommending the removal of the subsidy. In
an interesting exigesis of the outlook of the study, he explained,
. . . the study attempts to speak for quite a few groups, not only
the colleges and universities, even the bankers and State agencies
and the others that are all involved . . . (We] had to straddle the
fence on this because we were trying to speak for a half dozen dif-
ferent kinds of groups throughout the country.'
Mr. Kirkpatrick urged that the Guaranteed Student Loan
Program use a financial needs test. This was a central recommenda,
*The total bill was referred to as the Higher Education Amendmentsof 1968. Title IV, on financial assistance, was sometimes calledthe Educational Opportunity Act of 1968.
Hearings before the Special Subcommittee on Education of H.R.15067, part 2, p. 802.
83.
tion of the study. He explained it to the Subcommittee in terms
of the NDSLP's inability to fulfill the needs of lower-income
families. Therefore, the :=i..? was a "very, very valuable supplement
to the National Defense Student Loan Program." A needs test for the
GLP, based on the judgment of need by the colleges and universities,
was important to keep the money for those who needed it. Loans of
accomodation to higher-income families should be handled as loans to
the parent, not the student, through direct federal insurance
without the interest subs dy.* This poiat--in about one printed
page of testimony--was the crux of Mr. Kirkpatrick's testimony.
Mrs. Green herself cited the CEEB study three times during
the day. One mention concerned cancellation of loans for teachers.
She stated:
Mr. Gaul [associate general counsel of the committee] hascalled my attention to a pilot study that was done--it wasonly 109 borrowers under the NDEA. It asked, do you ex-pect that any of your loans will be cancelled because you areor will be in teaching? The total response, yes, 57 percent, and no, 43 per cent.
Then ves) is the fact that you do not have to pay back allyour loan influence your decision [sic] to go into teach-ing? Ninety-one per cent, no.**
on the second occasion, in a discussion of participation
of pri;:ole lenders in the Guaranteed Loan Program, she again
quoted the report directly. The statement dealt with the diffi-
culty of accurately assessing the availability of guaranteed
*Ibid., p. 803.
**Ibid" p. 770.
84.
loans to students,* and continues, "Participation by lending insti-
tutions does not necessarily mean a high volume of lending activity."'"
The other citation of the study by Mrs. Green also dealt
with the Guaranteed Loan Program. She stated that the study showed
the unavailability of loans in large population centers with a con-
centration of lower economic level families, predominantly Negro.
"I think this has been one of the most damaging bits of testimony
of how successful this program has been."***
*Through some mischance, the quotation in the Hearings inaccuratelysays "NDEA loans" rather than "guaranteed loans"; "guaranteedlt. Is" is the phrase in the study report and is deaandtd. by `:piesense of the statement.
**Hearings, p. 807.
***Ibid., pp. 808-809.
65.
Senate Reception of the Report: Respectful but Uninterested
The history of the Senate's reception of the CEEB report
contrasts with that of the House of Representatives. The
Senate Subcommittee was not in sympathy either with OE's
guidelines for the study nor with the CEEB's recommendations.
Accordingly, the attention accorded the study tended toward
the ritualistic.
Charles Lee and Roy Millenson, the staff members of the
Subcommittee, read through the report before its official
release on February 16, and on their recommendation it was
printed as a "committee print." Between 4-5,000 copies
were printed on standing resolution, as part of the "Notes
and Working Papers Concerning the Annirdstration of Programs
Authorized under Student Financial Asnistance Statutes." The
report was now available in a handy 6" by 9" printed paper-
back instead of only the bulky l" -thick mimeographed original.
The committee print, unabridged, unexpurgated, unchanged, was
dated March, 1968.
Where did the copies go? Many of them were used as
"stocking stuffers" for senatorial offices. Senators are
pleased to be able to send interested constituents evidence
of their efforts in their behalf. Senator Morse, chairman of
the subcommittee, was running in a strongly contested primary
election for the Oregon Senate-seat in May, and many of the
86.
reports were dispatched to Oregon voters. Others were mailed
out by subcommittee staff on request. Senator Javits, for
example, had copies mailed to a selected list of people in
education in New York. Because the staff is small and over-
burdened, no further formal distribution was initiated. But
they alerted the Office of Education to the committee print
so that OE could order additional copies from their funds at
a reduced rate. OE sent copies to all institutions of higher
education in the country.
In March and April, the Senate subcommittee staff held
conferences on student financial aid. In attendance were
staff members of the full committee, staff from the offices
of Senator Yarborough, Senator Prouty, Senator Dominick, and
other subcommittee members, Peter Muirhead and James Moore of
the Office of Education, John F. Morse of the American Council
on Education, representatives from Treasury, and others. The
purpose of the meetings was to consider issues of financial
aid, including the CEEB report and the perspectives ofAhe
Office of Education, United Student Aid Funds, and other
groupp.
What Mrs. Green and the House subcommittee.had done
formally by correspondence with Commissioner Howe, the
Senate Subcommittee did in informal meeting. The CEEB report
and the Office of Education positions on the report re-
commendations were discussed. In the recollection of
87.
participants, however, other issues, such as the reinsurance
proposal, received top priority.
The Senate subcommittee staff's reactions to the report
were that it was too conservative in outlook. Charles Lee,
the staff member of the r mocratic majority on the Committee,
saw Kirkpatrick as having the perspectives of a student
financial aid officer, with professional and emotional ties
to the needs criterion. The senators are student-oriented,
with a much less restrictive outlook. The Senate is inter-
ested in broadening aid legislation. Over time it has liber-
alized the provisions of the National Defense Education Act,
e.g., extending loan forgiveness to teachers in colleges and
universities, in private nonprofit elementary and secondary
schools, in overseas schools of the Armed Forces, and pro-
viding full forgiveness to teachers in low - income areas and
teachers of handicapped children. It has legislated
"educational opportunity grants", which are in effect scholar-
ships based on need. Cutback in the forgiveness feature or
restrictions on NDSLP were out of tune with the Subcommittee
orientation of increasing general support to education.
Nor is the Senate concerned with administrative efficiency
at the expense of programmatic effectiveness. Rationalizing
and centralizing administration of the loan progrars was not
viewed as a higher good. The Senate, with its long-run
perspective, is willing to tolerate a certain looseness of
68.
administration, particularly when programa associated with the
names and careers of sponsoring senators remain highly visible.
The CEEB report was seen as competent and well presented.
It "received consideration", according to subcommittee staff
members, not in political or partisan terms but in terms of
the issues facing higher education. Millenson, for the
Republican minority, emphasized that the report was not dis-
missed lightly. However, much of the thinking that..had ?shaped
the objectives and issues posed for the study by OE in 1967 was
irrelevant to Subcommittee deliberations in the Spring of 1968,
as were many of the CEEB conclusions.
The Senate hearings that began in March contained no
testimony directly on the study. Mr. Kirkpatrick, the study
director, testified before the subcommittee on March 13, but
he spoke from his extensive experience and did not mention the
study.
Two other witnesses alluded to its findings. Charles W.
Walker, executive vice president of the American Bankers
Association, cited the data on income level of :families re-
ceiving guaranteed loans.
... If I could steal some figures from a survey Mr.Kirkpatrick made, 58 per cent of 200,000 loanssurveyed went to families with $9,000 adjustedincome or lass. Thirty per cent went to familiesof :6,000 or less, and 12 per cent to familiesof 3,000 or less
U.S. Senate Hearings before the Subcommittee on Education of
These data, reported in the CEEB study, had been collected and
processed by the Office of Education.
Mr. Allen Purdy, director of student financial aid at the
University of Missouri and chairman of the National Student
Financial Aid Council, in his testimony referred to
Kirkpat;ickts study" as unable to find that teacher forgive-
ness had actually encouraged students to go into teaching.*
All other references to the CEEB study in the voluminous
Senate Hearings record (which ran to 6,584 pages with appen-
dices, 1,780 pages being directly on S. 3098) came from the
Department of Health, Education and Welfare concerning the
teacher cancellation provision.** In all three messages,
the position of the Office of Education and, the Department is
the same: The CEEB study found the evidence inconclusive on
the effectiveness of loan cancellation, and the Department is
not recommending its expansion.
There was one interesting exchange; between Commissioner
of Education Howe snd Senator Morse. Asked about extension of
forgiveness to the Guaranteed S4,Aident Loan Program, Commissioner
Howe gave what was now the stancrard answer.
the Committee on Labor and Public Welfare, Ninetieth Congress,Second Session, on S. 3098 and i. 3099, Education Legislation,1968, Part 2, p. 387
Ibid., p. 393
**Ibid., pp. 299, 543-44, 843.
90-
...We had an independ%nt study made on the for-giveness feature this past year. It is availablefor the record should you wish to enter it there.The study was done fr:, us by the College EntranceExamination Boar.; ca various aspects of loanprograms, including this one. The evidence is notconclusive concerning the effectiveness of forgive-ness features in bringing about the results thatthey try to achieve. It is apparently the judgmentof most student aid administators in colleges anduniversities that forgiveness programs are notparticularly effective, but that is again a matterof judgment rather than hard evidence.
SENATOR MORSE: I am aware of that study. We havealready pranted it as a committee print. I thoughtit was a very worthwhile study. The study itself,however, gives rise to some of these proposalsfor expansion.*
Senator Morse thus found support in the study for his position
of extending forgiveness, even though the recommendation was
antithetical. The study, before recommending the elimination
of the forgiveness feature, did indeed mention the equity of
extending it ta other "critical" professional fields and to the
Guaranteed Loan Program. And the data could be read as "in-
conclusive" on the positive side as readily as they could be
interpreted a$ negatively inconclusive. After all, 55 per cent
of the institttions of higher education replied that teacher
cancellation increased or probably increased the Lumber of
students at -she institution who went into teaching.
Ibid., pp. 543-544
91.
Action on the Higher Education Amendments
March was over and April passing. The loan programs would
expire unless new legislation was forthcoming, and neither house
had yet reported the education bill out of committee. The
chronicle of the next four months will involve (1) House passage
of a short form of the Higher Education Amendments dealing only
with financial aid, which soon dies, (2) House passage of the
omnibus bill with amendments, (3) Senate passage of a rather
different version of the bill, and then, faced by impending
adjournment for the political conventions and the expiration of
current legislation, (4) passage of a 90-day stopgap extension
by both houses. In the 1...gislative bustle, the House keeps
referring to te CEEB report and incorporating into its bills
provisions consonant with the recommendations. The Senate
ignores the report and passes contrary provisions.
(1) Short bill. On April 25th, in the House of
Representatives, the Committee on Education and Labor reported
out H.R. 16729, a new bill that sidestepped the controversies
around other educational proposals and provided the necessary
monies to continue only the aid programs. The bill extended
for two years the student aid programs (NDSLP, work-study,
educational opportunity grants, vocational student loan pro-
gram, and guaranteed student loam program) with minimal
92.
amendment. The bill had been reported by the subcommittee by
unanimous vote and by unanimous vote was approved by the full
committee.
In the report to the House that accompanied H.R. 16729,
the Committee offered a short background of the legislation.
It cited the 12 days of hearings during the 1967 session, 4 days
of which were concerned exclusively with amendments to the
guaranteed student loan program; 13 days of hearings in 1958;
mrneOUB communications from college administrators and local
lending, agencies, and in a sentence by itself:
The Committee has also given very careful considerationto an extensive study of federally assisted student aidprograms conducted by the College Entrance ExaminationBoard.*
One of the main changes incorporated in H.R. 16729 was
the increase in the maxim= interest in the Guaranteed Student
Loan Program from 6 to 7 per cent. The report cites four
sources of information. First was the House Subcommittee's
own study in 1967; results showed that there was difficulty
finding banks that would lend money under the GSLP and that
banks said the problem was the interest rate. Second was the
CEEB study. Data were cited from the bankers' questionnaire
showing that very few large or small lenders find GSL pro-
House of Representatives, Report No.1319, Extension ofHigher Education Student Assistance Programs, Report toaccompany H.R. 16729, p.3.
93
fitable. The third source of information was the "Barr Study",
the review of the GSLP by the interagency committee composed of
HEW, Treasury, Bureau of the Budget, and the Council of Economic
Advisors, headed by Joseph Barr of the Treasury. Finally,
testimony from the hearings was quoted in support of higher re-
turns to lending institutions. The CEEB study, thus, was one
of support among many for a position that practically everybody
now agreed was necessary.
The bill also adhered to the study recommendation that
NDSLP funds not be increased. The amount authorized for 1969
was $200 million, more than the $190 million appropriated for
1968 but less than the $225 million authorized for 1968. The
study was not cited. The study, in making its recommendation,
was responding to the same financial restrictions that con-
strained the committee in its budget proposal.
The report to the House also justifies the legislative
provision for advanced funding authority (i.e., including
appropriations for loan programs in the appropriation acts for
the fiscal year preceding the fiscal year in which funds are
made available), so that colleges can have early notificaticn
of funds available. This provision and its rationale are
consonant with the study recommendations, but the study is not
mentioned.
On May 9th, the House passed the bill extending the aid
programs. In Mrs. Green's statement in support of the bill,"41r,f,
she discusses -- as did the report from the committee -- the
Subcommittee's own study, the Barr interagency study, the CEEB
study, and the hearings testimony. All support the higher in-
terest rate. During the floor debate, Congressman Schwengel,
not a member of either the subcommittee or the full committee,
cited "a study by the College Entrance Examination Board" on the
costs of college for the student. Such information appears 3.n
the current report, but the figures are somewhat different. .
Apparently he was referring to an earlier CEEB publication. No
other mention of the report was made on the floor of the House.
So, with amendments growing out of the current anguish
over student demonstrations -- barring loans to students con-
victed of crimes against college property, to students who
refuse to obey college regulations and disrupt college ad-
ministration, and to persons convicted of rioting -- the bill
was passed.
There was still the big bill to consider and pass. This
included all, the controversial features on the loan programs
that H.R. 16729 had finessed, as well as titles dealing with
work-study and educational grants, cooperative education,
libraries, strengthening developing institutions, facilities,
etc. The subcommittee, in continuing its deliberations,
decided to put the little bill (H.R. 16729) back together with
the big bill. The student unrest amendments were the major
reason. The subcommittee wanted the opportunity to reconsider,
and probably water down, disciplinary amendments that had been
--4-ded on the floor.
95.
H.R. 16729 was now dead. The student assistance program
would make its next appearance before the House as part of the
omnibus bill, H.R. 15067.
(2) }.iSs22A.ssaeofttiilebibill. Titled the Higher
Education Amendments of 1968, the bill included the provisions
of the earlier version with only minor changes. Again it
provided for an increase in the interest rate for Guaranteed
Loans to 7 per cent, and again the Committee report cited the
CEEB study as one of the sources of support. The bill pro-
vided for advanced funding so that commitments to student
borrowers could be made in the spring. The amount of total
authorization for NDSLP went up from the $200 million of H.R.
16729 to $210 million in 1969, primarily to make VDSLP loans
available to vocational school students who were made eligible.
For 1970, authorization was $275 million.
Important new provisions appear in the bill. The interest
subsidy in guaranteed loans was eliminated during the re-
payment period; after he graduated, the borrower would pay
the full interest. This was an issue which the CEEB study
discussed sympathetically but did not take a position on.
No questionnaire data were collected relevant to the issue.
The big change was the removal of loan forgiveness for
teachers. Here the Committee report relied heavily on the
CEEB study. That Mrs. Green and the subcommittee had been
96.
resolved to end teacher forgiveness long before the study
appeared was a well-known fact. The study gave them prestigious
support and a little data.
The Committee Report states:
The committee has been unable to find statistical in-formation which shows that the forgiveness provision isan incentive to attracting or keeping teachers in theprofession. A study of Federal Student loan programsconducted by the College Entrance Examination Board ex-amined the problem. In title III of the study entitled"Summary of Findings and Recommendations", the CollegeEntrance Examination Board recommends that the "teachercancellation provision should be phased out." This studydiscusses the teacher cancellation in some detail andreveals that the staff was unable to find any clear-cutevidence that the teacher cancellation provision hasmaterially contributed to an increase in either thenumber of quality of teachers. The study also dis-cusses the administrative difficulties and confusioncaused by the provision ...*
The Committee Report goes on to cite the pilot study of
student borrowers from the class of 1965 in the metropolitan
New York area.
* House of Representatives, Report to accompany H.R. 15067,the Higher Education Amendments of 1968, Report No.1649,90th Congress, 2nd Session, July 8, 1968, p.43
97.
The language in the Committee Report wns succinct:
In discussing the CEEB study, mention was made of theresponse received to one questionnaire: 91 per centof the people responding replied that they were notinduced to go into teaching because of the teachercancellation provision.*
The Committee Report also dealt gracefully with the
Office of Education paper on the recommendation for loan forgive-
ness. It quoted the OE statement that
... Further study and evaluation of this aspect ofthe NDEA loan program might be done although thearray of attitudes and opinions in the educationalcommunity on this point is sharply divided, as forinstance, among deans of education, financial aidofficers, or loan recipients themselves.**
This was an indication that the Office of Education, which
called the CEEB study intonclusive, was not maintaining its
old opposition to cancellation. In saying that it had "no
additional information or data which will or will not support
the recommendation made by the college board," t.g* the Office
of Education could even be suspected of aid and comfort in the
effort to end cancellation.
Ibid., p.44
**Ibid., pp. 43-44
***House of Representatives, Special Subcommittee on Educ.ation of the Committee on Education and Labor, HigherEducation Amendments of 1968, Confidential Subcommittee,Print No.2, 1968, p.24.
98.
In the CEEE report, the House Subcomnittee had the first
solid information on which to stand. The study was a "salable
item", in the words of one informant, that provided justific-
ation for the committee's opinions. It 1,73.: therefore quoted
liberally.
The House 'All ended loan cancellation for general teaching.
On the other hand, it provided for full forgiveness for teachers
in slum schoo:s and teachers of the handicapped. This was a
modification If the so-called ProuiyAmendment (named for the
senator who originated it). Its rationale was clear: if loan
cancellation kss not an effective way of recruiting teachers,
it might still be an effective way to affect the distribution
of teachers -- and increase the numbers serving the poor. The
subject had not been considered in the CEEB Study.
On July 25, the House passed the bill by the lopsided
vote of 389-15. The CEEB study was not mentioned. Of the amend-
ments made on the floor, only one concerned the loan programs.
This was the amendment introduced by Mr. Scherle of Iowa on
student unrest. The committee had left to the discretion of
the college the cutting off of federal funds to student rioters.
The Scherle amendment required cut -off 'of loans and loan guarantees,
if the college or university determined that the student had
"willfully refused to obey a lawful regulation or order" of
the institution and "such refusal was of serious nature and
contributed to the disruption of the administration ". The House
was insisting on punishment for disorderly protesters.
99.
(3) The Si.;,14.e bill. Meanwhile, on the Senate side, the
education s.ibcomnittee was busy on its own amendments. The CEEB
study was nowher.! in evidence. No one during these busy days re-
members hearing the study even alluded to.
When the Senate bill was reported out of committee, it was so
altered from the administration-proposed version, S.3098, that it
was re- numbered. It was now S. 3769. The report accompanying the
bill made no mention at all of the CEEB study.
Little wonder. The major provisions in the Senate bill ran
counter to CEEB recommendations. Teacher forgiveness was not
dropped; forgiveness was extended. Teachers in poverty-area
schools would have their total NDSLP loan forgiven at the rate
of 20 per cent per year. Moreover, a new category of borrowers,
entrants into the armed forces, would receive loan cancellation- -
at the rate of 25 per cent for each year of military service.
These provisions were to apply not only to NDEA loans but were
extended to the Guaranteed Loen .Programs as well. Nor was NDSLP
to be held at its present level. The bill authorized $250
million for fiscal 1969, $275 million for 1970, and $300 million
for 1971 and 1972. Furthermore, a Presidential commission was to
be appointed to submit a plan for providing "universal educational
opportunity at the post-secondary level", presumably free to all
students.
The bill reached the floor of the Senate on July 15. No
mention was made there of the CEEB study. With two minor amend-
100.
molts unrelated to the loan programs, the bill was passed
unanimously, 83-0.
By the end of July, there were thus two omnibus education
VAen they were referred to conference committee, there
we seen to be approximatelyonehundred differences between
the House and Senate bills. The job facing the conference
committee was staggering. And the Congress was to adjourn on
August 3 for the political conventions.
(4) Interim extension. The staffs of both committees,
aware of the impossibility of reconciling the bills before
adjournment, asked the Office of Education what was absolutely
essential to pass. The answer: extension of the Guaranteed
Student Loan Program, which was expiring. In a few hours a
bill was put together to extend the GSLP for three months
and raise the maximum interest to 7 per cent. These provisions
were substitu:c.1 in the Senate for the language of the old
House-passed bill H. R. 16729. Without debate, both chambers
agreed to the interim extension.
101.
Passage of the Bill
When the Congress recc'rtvened after the political con-
vention, the Conference Committee returned to work on the
"Higher Education Amendments of 1968". In four days of meetings,
the last one running on into the night, it reached a series of
compromises between the House and Senate versions. During the
negotiations, the CEEB report faded from view -- except in one
instance. As we shall see, arguments on the issue of loan
forgiveness for teaching were so finely matched that the issue
teetered in the balance, and the report was brought into the
discussion.
The Conference Comndttee compromised on the amount
authorized for the National Defense Student Loan Program.
Authorization for NDEA loans was set at $210 million for 1969.
This was the figure in the House bill, rather than the $250
million set by the Senate. It exceeded the $190 million
appropriated for 1968. Higher sums were authorized for the
following years: $275 million for 1970, $300 million for 1971.
The CEEB study recommendations that NDEA loans remain at the
current level was by now outmoded; in 1968 there was little
controversy about a modestly increasing rate of federal ex-
, penditure.
The maximum interest rate on insured loans was raised
from 6 to 7 per cent. The CaB study was one iLtat of many
that led to what gas by now nearly unanimous agreement on
102.
increasing the return to banks.
Loan fo-giveness was the intractable issue. On two or
three different days, the conferees tried to resolve the
gaping differences between the House and Senate versions.
Finally, they agreed to settle all the other matters and return
to forgiveness at the end of their sessions. In the course of
the bargaining, the CEEB study was mentioned. Mr. William Gaul,
associate general counsel of the House Committee, recalls an
exchange between Senator Prouty and Mrs. Green. The senator
referred to the study to support loan forgiveness. Mrs.
Green's rejoinder was that the very study he was citing ended
by recommending that forgiveness be phased out. Apparently, the
"inconclusiveness" of the data was reflected in the arguments
of this ultimate decision-making body.
It was late at night on September 18 when, after further
fruitless discussions, the conferees decided that they could
not reconcile the opposing viewpoints. They felt that they
had a good bill, and "you can't do everything at once", so
they would stay with existing law. Thus, the final bill
left the existing provisions for forgiveness basically un-
changed. The study had had a chance to influence policy, but in
the final event it did not prove persuasive enough.
Two small revisions were made. One, forgiveness was ex-
tended for only two years although the loan program was ex-
tended for three. This is an indication of the unsettled
nature of the settlement. Second, a technical revision
103.
was made to allow more than 25 per cent of the schools in any
given state to be designated as poor schools, so that teachers
in the schools could become eligible for forgiveness, provided
that more than half the children enrolled met the proverty
criterion.
Other provisions of the final bill that accorded with
CEEB recommendations included forward funding, merger of the
Vocational Student Loan Program with the Guaranteed Student
Loan Program, further seed money to state agencies, federal
reinsurance of state loans, eligibility of additional lending
institutions such as pension funds, and elimination of the re-
quirement for special consideration in ND:ci.P loans for students
of superior academic background. On most m! these issues
(except forward funding), there were no reltreant data in the
study.
The bill ended subsidy of interest during the repayment
period. This was an acceptance of the House provision. While
the CEEB report had not actually recommended endimc the sub-
sidy, it discussed the subject sympathetically and concluded
that this was a "matter of possible future consideration".
Several of the important recommendations of the CEEB study
were barely considered. The study invested a good bit of
effort in making a case for a financial need criterion for
guaranteed loans, and for separation of loans of necessity
from loans of accomodation. In neither the executive nor
legislative branch did this proposal make any headway.*
The recommendation to consolidate administration of all
federal loan programs was also ignored. Actually the con-
solidation issue had been long and carefully considered in the
Department of Health, Education, and Welfare. One of the
questions posed to CEEB for study concerned the merger of the
loan programs, but the department had reached a decision be-
fore the study was completed that the health professions and
hursing programs should be kept separate from the OE -run
programs.
The Conference Committe bill was passed by both houses
of Congress. On October 16, 1968, it was signed by the
President and became law.
The Role of the Public Health Service
While the Office of Education and the Education Subcommit-
tee of the Congress were acting on the National Defense Student
Loan Program and the Guaranteed Loan Program, another federal
agency and other subcommittees were at work on revision and ex-
tension of the loan programs in the health field. The CEEB study
had examined these programs, the Health Professions Loan Program
(HPLP) and the Nursing Loan Program (NLP), which were the province
of the Public Health Service. But for a number of reasons, the
Public Health Service made relatively little use of the report.
The Public Health Service, through its Bureau of Health
Manpower, was a part-sponsor of the CEEB study: it paid $35,000
*A late note on delayed impact. William Gaul, after reading a draftof this report, reported in September 1970 that the concept of loansof necessity and loans of accommodation is by no means dead. It isbeing seriously considered for the higher education legislation of1970 or 1971. Apparently some recommendations have a longer ges-tation period than others.
105.
toward study costs. But the initiative was not its own. Direc-
tion had came from the Secretary's office. The $35,000 allot-
ment appeared in its budget along with the justifying paragraph:
A contractual study by the Office of the Secretary willsoon be made of all the Department's student loan programs.The study will determine the best methods of minimizingdirect Federal loans and maximizing the use of privateloan sources assisted by Federal credit such as guaranteesand subsidized interest rates. Cost to the student willbe maintained at a low level and access to loan assistancewill not be impaired by the new method of financing to bedeveloped. The study will also examine problems related tothe Feder State, and local administration of student loanprograms 81.1: e:e collection procedures, operational sim-plicit;1, azd il!t.errelationships with other forms of studentfinancial aid.'4
James Lovett, director of the Student Loan and Scholarship
Branch within the Bureau of Health Manpower, was involved in
early discussions of the study. He sat on the HEW advisory
committee that defined the issues that the study was to address.
Once the contract was let to CEEB, he participated in the review
of early drafts of the questionnaires. His PBS associates re-
call that he had reservations about the procedures and some of
the questions of the study, but he was reportedly told to "go
along" with the Office of Education.
When Lovett left his position for a job in the Chicago
Regional Office of PHS, his successor was not as closely involved.
George Warner became director of the Student Loan and Scholar-
ship Branch in July 1967, when the study was in midstream. He
inherited the file folders on the study, but it was his under-
Senate, Hearings before the SublvmmAttee of the Committeeof Appropriations, on H. R. 10196, PLstal Year 1968, Departmentsof Labor and Health, Education, and Welfare Appropriations, 90thCongress, first session, Part 1, Avril 10, 1967, p. 1228.
1o6
standing that OE was handling relations with CEEB. He was not
invited to the October Advisory Committee meeting in New York.
Shortly afterward, however, Thomas Brennan, special staff con-
sultant to CEEB, came down to PHS and consulted with Warner and
his branch. Marginals of the schools' questionnaire responses
on the health professions and nursing loan programs arrived
early in November, a month in advance of the Nashes' report.
Warner attended the December meeting of the Advisory Committee.
The flurry of involvement, however, never overcame PHS's sense
that this was OE's study, into which it had been reluctantly
dragged.
When the final report came in in January, the first two
recommendations were hardly calculated to gain the support of
PHS. The recommendations were to merge the operation of all
federal loan programs into a single administrative agency and
to merge the National Defense, Health Professions, and Nursing
Stucker:;:, Lima Programs into one. The Public Health Service, which
was obvit,zty not to be the beneficiary of the merger, might be
forgiven for viewing the rest of the report with some reserva-
tion. Although the staff did not say so directly, there were
intimations that they harbored suspicions that empire-builders
at OE might have influenced the CEEB to see such recommendations
as logical and efficient.
The CEEB study was more cursory in its attention to the
Health Professions and Nursing Student Loan Programs than to
NDSLP and GLP. Relatively few of the recommendations dealt with
the health programs. Besides the first two on the merger, there
were seven recommendations that were relevant. They were: re-
107.
vising the institutional allocation procedure for health profes-
sions schools, earlier availability of loan funds, consideration
of factors to make the revolving fund acceptably operable, pro-
ceudres for improving loan collection (although HTSLP and NSLP
were too new for collection to be much of an issue), greater
uniformity of provisions among loan programs, ending nursing
cancellation, and greater efforts to disseminate information on
nursing loans. PHS staff viewed most of these recommendations
as either superficial or as afterthoughts from the study of
NDSLP and GLP; that is, recommendations relevAnt to OE programs
were being tacked on to their programs without any sensitivity
to the special needs in the health field. For example, there
was reason to believe that nursing students, recruited fro;
lower-income groups than teachers, found loan forgiveness an
important incentive to entering nursing.
The Health Manpower Act of 1968
None of the CEEB recommendations directly incorporated
into the new legislation that PHS drafted--the Health Manpower
Act of 1968. The bill, introduced into t1 Congress in Marc._
provided federal assistance for health education and trcining,
including extension (with some modification) of the Health
Professions and Nursing Loan Programs.
In the Senate, the bill was referred to the Health Sub-
committee of the Committee on Labor and Public Welfare. This
was the same committee that, through its Education Subcommittee,
had had the CEEB report printed as a Senate document. The
1o8
Health Subcommittee therefore was aware of the report's existence
and its general nature. In fact, Senator Javits, who sat on both
the Education and the Health Subcommittees, found support in the
report for one of his pet projects. For some time his aieLe,
Roy Millenson, had been pressing for greater consistency of pro-
visions among loan programs. They saw the CEEB report as a tool
to prod the Department of HEW to move toward that end. They
asked the Public Health Service to comment on the CEEB recommenda-
tions regarding consistency. When the department did not come
in with much improvement in consistency, Senator Javits brought
together the majority and minority members of the Senate commit-
tee, staff of OE, PHS, and HEW. He got agreement to a set of
amendments to align discrepant provisions. The Javits Amend-
ments to the Health Manpower Act were accepted by the Congress.
The exact provisions recommended by the CEEB report were
not always adopted. For example, the report recommended a
grace period of four months after graduation before repayment
began. The Congress agreed to a period of nine months for nurses
(down from one year) to make the NSLP equivalent to the NDSLP,
and one year, rather than three years, for health professions
students. But the report focused on discrepancies, which the
Javits Amendments to some degree resolved. The Health Manpower
Act achieve, ereater conformity in length of the grace period,
loan ceilings, minimum repayment, interest rate, and deferment
of repayment during VISTA service. Interest rates, for example,
were reduced to the level of the NDSLP. As Millenson said, "The
109.
report gave us ammunition to hit the department in order to bring
the support programs into line."*
The consistency recommendations were the only CEEB recom-
mendations to have an impact. The recommendation that forgive-
ness of nursing loans be terminated, which was opposed by PHS,
WAS not accepted. In fact, the bill, as passed, liberalized
the forgiveness provisions. The total nursing loan could now
be cancelled at the rate of 15 per cent for each year of service
as a nurse in a hospital in a highly populated area with a
"substantial shortage" of nurses. The existing provision,
allowing cancellation of 50 per cent of the loan at the rate of
10 per cent a year, was retained for professional nurses employed
in any public or nonprofit institution. The CEEB recommendation
that administration of all loan programs be consolidated was not
considered. The CEEB report was not mentioned in the Senate
report on the Health Manpower Act, nor did it figure in debates.
By the time the bill was taken up in the cognizant sub-
committee in the House of Representatives (the Public Health and
Welfare Subcommittee of the Jommittee on Interstate and Foreign
Commerce), the Javits amendments had already been incorporated.
House staff member James Menger had seen the CEEB report and was
aware of its recommendations, but since the Javits amendments
were already in the bill, he saw no reason to bring the report
to the attention of overworked subcommittee members. The loan
provisions were only one small part of a large and complex bill,
*Subsequently, when the Higher Education Amendments of 1968 werepassed, some of the new consistency disappeared. Lg., VISTAservice was not included in the list of grounds for defermentof repayment in HPSL and IWL.
110.
and the changes proposed were relatively minor. Moreover, leg-
islative staff members seemed to have a general skepticism
about the practicality of "academic studies." Immersed in
pv,4ticalities, they are very of academic preoccupation with
theory, logic and neatness.
The House subcommittee accepted the Senate version on the
loan provisions. No changes were made by the full committzq or
0.1. the floor of the House. In August the House passed the Health
Manpower Act, the Senate acceded to the House bill, and the
President signed the bill into law.
Chronology - Phase III
Decisions Are Made
Congress
1968
Feb. - Higher Education Amendmentsof 1968 introduced into House.
March -Bill introduced intoSenate.
Senate prints CEEBreport as govern-ment document.
Feb.-March-Hearings in bothhouses.
March-Health Manpower Actintroduced.
May-House passes extension ofloan programs.
June-Senate passes HealthManpower Act.
July -House passes Higher EducationAmendments of 1968. Senate passesits version.
Bureau ofOffice of College Entrance Applied SocialEducation Examination Board Research
March-OEtakes positionon CEEB recom-mendations
Feb. - Sends copiesof report to Houseand Senate sub-committees on edu-cation.
March-Kirkpatricktestifies beforeHouse and SenateSubcommittees.
Mu-MailsCEEB report tocolleges and uni-versities.
-Both houses pass interim extensionof Guaranteed Loan Program for 90 days.
hm.-House passes Health Manpower Act.Senate concurs in House version. Presi-dent signs.
fut.-C,)eer4nce Committee reconcilesdivergent LIUs; both hoves pass theHigher Education Amendments.
Oct.- President signs the bill.
112.
Scoreboard: Did Survey Data Increase the Utilization of the
AzaStuRecoez.dais?
With the deciaions on loan legislation made (at least for
the next two or three years), it is possible for us to examine the
question of whether the survey data had an impact on policy. Be-
cause some CEEB recommendations were backed by quantitative data
and others were not, we can compare the fate of the:two sets of
recommendations to see whether this kind of research backing in-
creased the likelihood of utilization. Figure 3 presents the
relevant information.
Figure 3, and Figure 4 which summarizes the information,
show that in this case it made little difference whether or not
there were data to support the recommendation. One of the three
recommendations supported by research findings, and one out of
three recommendations with no research support, received Office
of Education acceptance. Identically, one out of three recom-
mendations supported by research findings and one out of three
with no research support, were enacted into law.
On the other hand, where there were data antithetical to tree
recommendation, none--out of four--was enacted. It may be doubted,
however, that this indicates the reverence of the Congress for
research. Some of the inaction on survey-contradicted recommen-
dations was happenstance. The increase in NDSLP was made possi-
ble by the loosening of the budget restrictions. The lack of
consolidation of loan program administration probably reflected
Congress' disinclination to meddle with executive administrative
arrangements that were functioning adequately. Teacher forgive-
ness was a near thing.
Figure 3
Fate of Twelve Controversial Recommendationszdf the CEEB Study That Required Legislative Action
Recommended by CEEB
Financial need should be a criterionfor GSL.
Colleges should determine who receivesGSL and recommend amount.
Banks should receive higher returnthan 6 per ceal..
Grace period should be shortenedafter graduation.
States should set up central servicedivision or pool of credit for studentshaving difficulty obtaining guaranteedloans.
Loans of accommodation for non-needyfamilies should be separately adminis-tered.
Supportedby survey
data?
Yes
Yes
Yes
Somesupport
Somesupport
No data
Removal of interest subsidy during re- No datapayment period might be considered forthe future.
Combine 6 loan programs into two
All loan programs should be adminis-tered in one federal agency.
NDSLP should not be cut or increased.
Loan forgiveness for teachers shouldbe ended.
Loan forgiveness for nurses shouldbe ended.
No data
Accepted byOffice ofEducation?
No
113.
Passed,
by the
2925E2E11
No
No (although Nothey can andshould beconsulted)
Yes Yes
Yes, but notproposed inthe Adminis-tration bill
No--veryineffective
No
Yes--willconsider
No
Some Not atcontradiction this time
Somecontradiction
Somecontradiction
No
OE said datainconclusive;did notrecommend
Some Did not corn -
contradiction went on PHS
Program.PBS opposed.
In healthprogremsonly andthe% notdrastically
Direct fed-eral insur-ance made'mailableto meetsuch prob-lems
No
Yes--subsidyeliminated
No
No
No
No
No
114.
Figure 4-
Relationship of Research Supportto Enactment of CEEB Recommendations*
CEEBrecommendation was:
Passed Notinto law Fused
Supported by data 1 2
No data 1 2
Contradicted. by data - 4
*Two recommendations, grace period and state credit pool, are notincluded because they defy classification.
115.
On balance, the surveys do not appear to have made much dif-
ference in utilization. But two qualifications should be added.
The recommendations that lacked surrey support were based on CEEB's
own fact-gathering and opinion-gathering interviews and meetings.
As such, they were not markedly different in origin from the survey-
supported recommendations. Secondly, as indicated on page 64,
even the strongest and most relevant survey backing for a recommen-
dation in this study hardly constituted conclusive evidence. At
worst, the survey support was tangential and inferential; at best
it was based on the opinions of respondents whom some deemed in-
sufficiently informed to have the final say.
Other Effects of the Study
If t1' study had some limited effects on the 1968 legislation,
it also had other conszquences. It informed staff members of the
Office of Education's Division of Student Financial Assistance and
the Public Health Service's Student Loan and Scholarship Branch of
the views of institutions affected by the program. Several staff
members in both PHS and OE turned to the computer tables, the
detailed cross-tabulations, to help understand who was satisfied
or dissatisfied with various aspects of the programs--by state,
size of institution, type of program, auspices.
There were a good many detailed questions in the question-
naires that provided important information. For example, institu-
tions of higher education were asked how they determine a student's
financial need, what their criteria are for awarding NDEA loans and
educational opportunity grants, whether they make repayment arrange-
116.
ments for loans before the student leaves school, how often they
bill, whether they assess penalty charges to delinquent borrowers,
whether they release transcripts of students delinquent in repay-
ment, whether they use collection agencies, etc. Much of the data
was closely analyzed by staff, so that it contributed, to some
degree, to better informed management of the programs.
Although they find it hard to point to any administrative de-
cision that was directly influenced by the study, officials indicate
that they benefited from the study data. Dr. Peter Muirhead,
Associate Commissioner for Higher Education, thinks that administra-
tively the study was particularly useful in highlighting the charac-
teristics of students obtaining assistance, in collecting data on
the packaging of loans with Educational, Opportunity Grants and
College Work-Study, on problems between OE and state agencies, and
on the unavailability of guaranteed loans to out-of-state and part-
time students. As Dr. Halperin said, had there been any real
scandalssay, NDEA loans going in large numbers to middle-income
students--immediate and drastic action would have been taken. But
there were no real surprises in the report. The programs were
working well. Even the Guaranteed Loan Program, which was signed
into law only on November 8, 1965 and was very new in operation,
was succeeding relatively well. So the kinda of administrative
steps called for were small and undramatic. But for the managers
of the programs, the report was useful nonetheless.
The Public Health Service staff also used both the report
and the more complete Nash data in analyzing current practice and
attitudes in health professions and nursing schools. They found it
117.
very useful to learn the criticisms and comments of their consti-
tuents.
The Office of Education has already used the study in connec-
tion with proposals of other agencies that affect the NDEA loan
program. Over the years there ;lave been many proposals to extend
loan forgiveness to scarcity pzfessions besides teaching and
nursing. The latest was incorporated in a bill sponecred by the
Department of Defense, which provided loan forgiveness to men who
become Army officers. The Bureau of the Budget consulted OE on
the provision. OE, leaning on the CEEB study, replied that there
is no conclusive evidence that forgiveness increases the supply of
teachers, so it is not likely to work for Army officers. The
Bureau of the Budget then did not clear the bill as an Administra-
tion bill.
Copies of the study were mailed to every institution of higher
education in the country by the Office of Education. To the extent
that financial aid officers learned more about current practices,
alternatives, and proposals for improved administration, it is at
least remotely possible that the study helped them in their prac-
tices. It is more probable that filling out the questionnaire had
an impact. Financial aid officers at every institution of higher
education were asked to complete the study questionnaire, and as
Patricia Nash suggests, the very consideration of the question is
likely to have an educational effect. It would no doubt be diffi-
cult to locate and identify changes in the practice of any financial
aid officer stemming from confrontation with the questionnaire or
with the report. But the possibility of such changes exists.
118.
Banks, too, were not unaffected. Mr. Kirkpatrick recalls re-
ceiving an inquiry from the officer of a Virginia bank who had
read about the study in a publication of the Boston Federal Re-
serve Bank. He wanted to learn more about the Guaranteed Loan
Program and his bank's possible participation in it.
As for further policy impact, it is certainly possible that
the study will be referred to in future years as new legislation
is considered. Roy H. Millenson, Minority Clerk of the Senate
Subcommittee on Education, said, "There are always a few nasty
people like me around who keep old reports and bring them up."
He suggested that much depends on the election and on changes in
personnel. If the next Commissioner of Education served on the
CEEB study Advisory Committee, he may come in strongly committed to
some of the study's views.*
Members of OE staff feel, too, that the study will have in-
fluence in the future. They say that in some areas it provides the
best data to date and will keep being referred to.
Members of the Public Health Service staff also expect to use
the report further. One use they foresee is to meet, in part, the
requirement of the Health Manpower Act of 1968 that calls for "ap-
praisal of the programs . . . in the light of their adequacy to
meet the long-term needs for health professionals . . ." by July 1,
1970. The CEEB study gives some information on what health pro-
fessions schools are currently doing and provides a baseline for
study of changes in ensuing years.
*William Gaul's report of the surfacing of the distinction betweenloans of accommodation and loans of necessity in 1970 (see foot-note, page 104) is an illustration of later utilization of thestudy report.
119.
Chapter - IV
CONCLUDING COMMENTS
Amid all the complexities in the situation, there were certain factors
that fostered utilization of the CEEB study. First was the nature of the
College Entrance Examination Board itself. It is a prestigious organization
recognized as a legitimate spokesman for the interests of the higher educa-
tion community. It had, with the Bureau of Applied Social Research, done
previous research on financial aid that was well received. Its staff, advisors,
and consultants were knowledgeable, often recognized and respected authorities
in the field.
However, in some respects the "educational identification" could
have been a handicap. Those persons whose constituents were not institutions
of higher education (e.g. staff of the Insured Loans Branch of OE who deal
with banks, Senators, Representatives, staff of the Public Health Service)
occasionally had twinges of suspicion that because of CEEB's character and
history, colleges were being overrepresented at the expense of other groups
in the system. There was an occasional worry that CEEB would "play it safe"
so as not to antagonize its constituent institutions. Voiced once or twice
was the suspicion that OE was calling the shots too closely, with a view to
shaping the nature of the conclusions. CEEB might stand still for this because
they have to maintain a continuing relationship with OE in the course of many
of their operations.
As it turned out, none of these incipient suspicions had much of a
career. Thy battle lines were never drawn in terms of educators vs. every-
body else. Early doubts about fairness and neutrality evaporated.
Another support for the study came from its agreement with the results
120.
of an earlier questionnaire survey conducted by Mrs. Green's subcommittee.
The tenor of these results closely paralleled the much larger inquiry of
CEEB and lent credence to both sets of data.
The style of the CEEB report can be credited with some positive re-
actions. Although not many people read the whole report unless their job
required them to, the style was clear and readable, and the organization of
the report around the recommendations facilitated easy referral. This was
lay language, designed for a lay audience, written by Kirkpatrick with an
eye on the needs of the client. The original questions of the study were
not bent or subverted by research professionals writing for a professional
research audience. Nash comments, "No one asked: What is sociological about
this?" The study served the purposes for which it was funded, rather than as
a source for academic prestige and rewards.
In its concentration on the client's questions, the study never stepped
back and took a look at the issues from a higher level of abstraction. It
did not reflect either a theoretical sense of structure and process, nor did
it deal with the overarching political concerns. For example, it did not"
consider such larger and important issues as ways of financing higher education
over the long run--and how student loans figured in the pattern. It looked
at practical issues, operational issues, not at what was the best approach to
assistance. Because of its practical stance, the study avoided some of the
political hot potatoes. It gained in "objectivity." It may well have lost
in relevance and long-run illuence.
That the conclusions of the study were largely favorable to the
*House of Representatives, Report of the Special Subcommittee on Educa-
tion, Study of the United States Office of Eaucat*ion, 89 Congress, 2nd session,1967, pp. 141-201, 471-584..
121.
federal loan programs certainly had some effect on utilization. They evoked
little resistance from staff and legislators committed to the programs. On
the other hand, neither did they provoke any immediate and active response.
The programs were functioning well enough, according to the study, to need
relatively little change. Legislators found it hard to see much real pay-off
in the lives of people by tinkering with minor provisions of the law.
One of the factors that Kirkpatrick cited as fostering use of the
study was the government's need for answers. Questions were pending, and
the "users" were waiting for results to come in. In actual fact, the users
were not waiting in quite such breathless anticipation as the OE task state-
ment suggested. Staff work was not halted while the study was in progress.
In fact, some of the most basic decisions on the programs were made before
the data were in: merger of loan administration was dropped, 1968 legislation
was drafted. The frame of the debate was changed during 1967, so that phasing
out of NDSLP, which was initially a major issue for the study, became irrele-
vant. In January, 1968, the report was answering some questions that no one
was asking and fighting some battles that had faded from sight.
The timing of the study was poor from the point of view of the legis-
lative planning cycle. Had it been completed four months earlier on the
schedule originally proposed, it would have arrived when new legislative pro-
posals were being prepared. There is little question that it would have been
used more extensively in developing and legitimating legislation.
Nevertheless, many of the issues were still alive and pressing. If
the users were not avidly expectant, they were still interested. The history
of some of the provisions (e.g. teacher cancellation) bears witness to the
fact that relevant data were pounced upon and cited repeatedly.
122
The ability of the study to chsea opinions is nowhere in evidence.
Its capacity to reinforce existing positions is repeatedly seen. Senator
Javits found support for conforming provisions. Mrs. Green found support
for ending teacher cancellation, OE found support for quietly easing out from
teacher cancellation, Senator Morse found support for extending cancellation.
Bankers found support for higher interest rates.
In some cases the study identified problems, and new solutions were
found. One example: out-of-state students had a lot of difficulty getting
guaranteed loans. The Higher Education Act of 1968 has a new provision to
remedy the situation. In cases where the borrower, by reason of his resi-
dence, does not have acceos to the state's GSLP, the Commissioner of Education
can insure the loan directly.
Would the study have had greater impact if it had collected more
objective, rigorous evidence? Asked this question directly, most informants
begged the question by saying that, given the newness of the programs and the
restrictive time schedule, the study was the best that could have been done.
Several informants claim that harder data would have strengthened the in-
fluence of the study. It would have given proponents of positions better
ammunition and might have had significant consequences, such as ending teacher
forgiveness. The most outspoken informant claims that it was on the forgive-
ness issue that the study had its main chance of influencing events because
the pro and con positions were so evenly matched. By relying so heavily on
opinion, it muffed its chance.
Whether any study can alter commitments based on strong ideological
considerations remains moot. Stember in a recent article on evaluating class-
room integration makes explicit what many people suspect.* Evaluation of
Wrtr.mmws,
*Charles Herbert Stember, "Evaluating Effects of the Integrated Class-
room," The Urban Review, Vol. 2, June 1968, pp. 3 -4, 30-31.
123.
the balanced classroom, he says, is not likely to show positive results on
racial attitudes. Whether or not it shows that learning improves, or at
least does not decrease, "remains inconclusive." But why should decisions
be affected by poor evaluation results on criteria of either racial harmony
or learning? Integration is ethically and legally right as a principle of
democracy.
In just such ways can the basic rationale be shifted on any question.
If loan forgiveness does not increase the supply of teachers, it can still
be justified as rewarding members of low-paying but vital professions, or
as a step toward free higher education for all. Research results that con-
flict with strong commitments or strong interests of actors in a social
system are unlikely to make m4ch headway unless aided by strong allies.
In this case, allies existed ready-made. It will be important to see, in
other cases, what it takes for research to create allies (out of neutrals,
out of opponents) who will utilize its conclusions.
A-1
APPENDIX A
TASK STATEMENT FOR THE STUDY OF FEDERAL LOAN PROGRAMS
A. Federal Policy on Student Loans
1. The Federal Government. as a matter of public policy, has fostered
studbnt loans as a principal means of providing assistance to needy students,
and is now extending benefits of loans to students from middle-income
families not previously eligible so that additional students will attend
college.
2. The Federal policy is to minimize direct loans financed from the
Federal Treasury, and maximize loans through private financial sources as-
sisted by Federal credit such as guarantees and subsidized as to interest
rate in order to keep the cost to the student low, and minimize the dif-
ference in cost to the student between a direct Federal loan and guaranteed
loan.
3. The Federal Government has provided for student loans under- -
(a) Public Law 85-864, title II of the National Defense Education
Act of 1958, the NDEA student loan program;
(b) Public Law 88-129, title III, part C, of the Public Health
Service Act, as amended, the health professions student loan program;
(c) Public Law 38-581, title VIII, part B, of the Public Health
Service Act, as amended, the nursing student loan program;
(d) Public Law 89-329, title IV, part B, of the Higher Education
Act of 1965, Federal, State, and private programs of low-interest loans
to students in institutions of higher education;
(e) Public Law 93-287, the National Vocational Student Loan
Insurance Act of 165, Federal, State and private programs of low-
interest loans and direct Federal loans to vocational students;
(f) Public La:, 87-510, Refugee and Migration Assistance Act of
1962, 146, loan program for Cuban students.
-2
B. Objective of Study of Federally Assisted Student Loan Programs
This study is to gather information and evaluate factors bearing on the
organizations and operations of federally supported student loan programs in
relation to the policy guides given above. The evaluation will cover ad-
ministration of the student loan programs, the problems of student loan col-
lections, and other significant areas of student loan operations. In total,
the study will develop and propose measures to make federally assisted student
loan programs best serve the Nation's broad educational objectives.
To the extent these measures call for revisions in existing legislation
specific phasing plans for the transition will be formulated for action on
a step-by-step basic to avoid any setback or disruption in meeting this ex-
panding need for student financial aid.
The optimum operational conditions desired from the federally assisted
student loan programs will- -
(1) assure students eligible under Federal policies access to loans
to be used to enter upon or further their college education;
(2) provide maximum administrative simplicity with the cost of
operation of the program held to an economical level;
(3) assure a businesslike approach that will result in collection
of loans with minimum collection losses;
(4) create effective administrative relationships and harmony among
the parties; that is, the Federal Government, the educati,,,nal institu-
tion, the State or private guarantee agency, and the lender, in meeting
the needs of the student;
(5) facilitate maintenance of appropriate interrelationship with
all other forms of student financial aid, scholarships, grants, work-
study or other student employment programs, or precollege savings
programs.
4'-3
C. Key Study Problems
The study of etudent loans should- -
(1) determine appropriate administrative structure, responsibilities,
relationships for Federal participation, including measures for cefective
decentralization of operations in student loan programs through :!nvolvement
of State and private nonprofit institutions, educational institutions, direct
or indirect Federal involvement with lending institutions, or some combina-
tion of these arrangements;
(2) consider the operating responsibilities of the educational in-
stitution, the lending institution, the loan guarantee agency (Federal or
non-Federal) in financial dealings with the student borrower. Among the
factors involved for which responsibilities among the parties are to be
determined are (a) financial eligibility, (b) amount of loan, (c) disbursement
of loan funds, (d) repayment arrangements, (e) collections, (f) determination
of default, (g) application of penalties and default provisions, and (h)
institution of guarantee provisions;
(3) examine alternative arrangements for administration of the student
loan forgiveness because of teaching, practice of medicine in rural areas,
or other elements of public services which the Congress has determined to be
eligible for forgiveness;
(4) assess factors affecting supply of private credit to meet needs
of applicants for student loans, and evaluate measures to increase supply of
credit, including, among others, interest rates, reserves to meet defaults,
coverage of guarantees, eligibility of student loan obligations for dis-
counting in the credit market, repayment conditions, streamlining administra-
tive processing and reporting;
(5) assess existing restrictions facing educational institutions in
t-4
borrowing for purposes of financing student loans with Federal guarantee of
repayment of principal and interest. Propose measures to assure that loans
under credit shortage conditions will be made to applicants having greater
needs, giving consideration to modifying eligibility standards for Federal
loan assistance, including availability of liquid assets of the family, as
well as income in determining eligibilities, use of sliding scales of
Federal assistance related to financial conditions of family, or other means
of establishing priority or preference for student loan applicants in need;
and
(6) examine special problems of and propose measure for assuring
private credit to minority groups, and students from families without favor-
able or established credit records.
APPEBDIX B
Successive Drafts of Recommendations of the Study of Federal Student Loan Programs
on the Guaranteed Student Loan Program
OCTOBER 9
Direct federal insurance
where :were is no effective
state plan militates against
state funding of guarantee
agencies, and in all cases
works against appropriation
of state funds.
Lack of financial need cri-
terion in GSLP prevents
lending institutions from
using limited funds for the
more needy students.
Threatens to dry up avail-
able credit.
Loans of convenience should
not be charged as federal
aid to higher education.
Such loans "will be taken
advantage of and used for
other than educational ex-
pensea.
Colleges and universities
should have the responsi-
bility for meeting finan-
cial needs of needy
students.
OCTOBER 20
Direct federal insurance has
been a deterrent
to action in
many states.
*End direct federal insurance
after June 30, 1970.
*Bring in incentives to en-
courage strong state agencies:
-Enact proposed SO% fedora;
reinsurance plan.
-Make additional seed money
available to the states.
-Task force should visit states
with weak or no guarantee
agency to explain methods.
Financial need should be a
criterion of OSLP.
Separate loans of necessity
from loans of accommodation.
The latter should be adminis-
tered by a separate federal
agency.
Colleges and universities
should he responsible for de-
termining which students
should rec(!ive GSL and recom-
mending how much they should
get.
DECEMBERS
Strengthen state agencies.
*End direct federal insurance
after June 30, 1970:
*Bring in incentives to en-
courage strong state agencies:
-Enact proposed 80% federal
reinsurance plan
-Make additional seed money
available to states
-Consider federal sharing of
costs of administering
state program.
Financial need should be a
criterion of GSLP.
Separate loans of necessity
from loans of accommodation.
The latter should be adminis-
tered by a separate federal
agency.
Colleges and universities
should be responsible for de-
termining which students
should receive GSL and recom-
mending how much they should
get.
FIMAL REPORT
Strengthen state agencies.
*End direct federal insurance
after June 30, 1970.
*Bring in incentives to en-
courage strong state agencies:
-Enact 80% federal reinsurance.
-Make additional seed money
availetle to states
-Consider federal sharing of
costs of administering state
programs
-Hold conferences on OLS
with state officials.
Financial need should be a
criterion of GSLP.
Separate loans of necessity
from loans of accommodation.
The latter should be adminis-
tered by a separate federal
agency or through direct
federal insurance.
Colleges and universities
should be responsible for de-
termining which students
should receive GSL and reel.,
mending how much they should
get.
APPENDIX B - continued
CCTOBER 8
Loans at 6 percent are
not profitable for many
lending institutions
Loans are not available in
many cases because many
banks don't participate,
banks have loaned their
maximum, they require an
established account or
relationship with the
lender, they discourage
students from low-income
families and racial
minorities, and/or state
residency requirements
rule out loans for out-
of-staters.
OCTOBER 20
GLP cannot be soundly based
unless loans are put on a pro-
fitable or, at least a break-
even basis for lending in-
stitutions.
A study should be made of fac-
tors to be considered in pro-
jecting demands for loans un-
der GLP.
Clear-cut need to
broaden sources of loan funds,
e.g. pension funds, insurance
companies, college funds, re-
venue bond issues, state credit
pool, etc. States might set up
a central service division, or
central pool of credit to
handle special cases.
DECEMBER 4
Loans should provide a rea-
sonable profit to lending
institutions.
A task force should identify
elements to be considered in
projecting need for funds and
each state should prepare 5
year projections.
OE should enter into agree-
ments with insurance com-
panies, credit unions, uni-
versities, to increase loan
funds.
States should be encouraged
to set up central service di-
vision, or central pool of
credit, to provide loans for
students having difficulty
obtaining loans.
States should be advised of
methods for providing new
and supplementary sources
of funds.
FINAL REPORT
Loans should provide a rea-
sonable profit to lending
institutions.
A task force should identify
elements to be considered in
projecting need for funds and
each state should prepare 5
year projections.
OE should prepare projec-
tions of demand for student
loans for next 5 years with
assistance of state agencies
and institutions of higher
education.
OE should enter into agree-
ments with insurance companies,
credit unions, universities,
to increase loan funds.
States should be encouraged
to set up central service di-
vision, or central pool of
credit, to provide loans for
students having difficulty
in obtaining loans.
States should be advised of
methods for providing new
and supplementary sources of
funds.
States should make
greater efforts to gain in-
created participation by
lending institutions.
APPENDIX B - continued
OCTOBER 9
(Nothing on
occupational
forgiveness)
(Nothing on
interest
subsidy)
OCTOBER 20
Loan forgiveness for teachers is
difficult to administer. To add
it to GLP would be "very burden-
snme." Questions have been raised
about removing it from NDSLP be-
cause it is difficult to prove that
it attracts individuals to teaching
and because other professions want
cancellation.
Some advocate removal of interest
subsidy during the repayment period.
Removal would increase the incentive
to repay promptly.
Inotttutions of higher learning
would like GSL eligible for matching
with educational opportunity grants.
Proposed merger of Vocational Student
Loan Program and GSL -is very desir-
able.
Larger banks think the grace period
should be reexamined and recommend
reduction to 90 days after gradua-
tion.
Educational institutions favor a
change in the once-a-year disburse-
ment of GSL to each semester, tri-
semester, or quarter.
Payment of GSL directly to students
is criticized by many colleges and
universities.
Maybe GSL should be
mailed directly to the institution.
DECEMBER 4
Occupational forgiveness,
especially teacher forgive-
ness, should not be extended
to GLP.
Reexamine and consider end-
ing the interest subsidy
during the repayment period.
Make GSL eligible as match-
ing funds for educational
opportunity grants.
Enact proposed merger of
VSLP and GLP.
Shorten grace period.
Make loans payable in two
installments a year.
Loans should be sent to the
student in care of the in-
stitution.
FINAL REPORT
Do not extend forgiveness to
GLP. Eliminate occupational
forgiveness for teaching and
nursing from NDSLP and NSLP.
Removal of interest subsidy
during the repayment period
is a matter of possible
future consideration.
Make GSL eligible as matching
funds for educational oppor-
tunity grants.
Enact proposed merger of VSLP
and GLP.
Shorten grace period to four
months.
Make loans payable in two
installments a year.
Loans should be sent to the
student in care of the
institution.
C-3.
APPENDIX C
FORTY -FOUR CELB RECCMMENDATIONS CLASSIFIED BY DEGREE OF SURVEY SUPPORT
Supported by the Survey
Financial need should be a criterion for GSL.
Colleges should determine who receives GSL and recommend amount.
Banks should receive higher rate of return on GSL.
Forward funding by Congress to allow earlier notification to institutions of
amount of loan funds.
New maximum loan limits.
Some Support from the Survey.
Shorten grace period after graduation to 4 months for all loan programs.
(Half the banks say 10-month grace period not excessive for GLP, but 3/5 of
large commercial banks who do most lending say it is. Colleges weren't
asked.)
Encourage states to set up.central service division or pool of credit for
students having difficulty obtaining loans. (Survey documented problem, not
solution.)
Simplify and standardize reporting procedures. (Colleges weren't very dis-
satisfied.)
Extra-legal loan restrictions on NDSL should be discouraged. (Survey showed
only that restrictions exist.)
Change procedures in GLP, e.g. send money care of college, make payments twicea year. (Colleges favored, banks split.)
Strong encouragement should be given to use of centralized collection agenciesfor NDSL: HPSL: NSL. (Half the schools favored, but few used or were consider-ing use.)
States should encourage greater participation in GIP by lenders.
Survey Irrelevant
Separate loans of accommodation from loans of necessity and administer theformer separately. (Follows from need criterion for GSL if middle-incomefamilies are to be served.)
Appendix C - continued C-2
Change federal allocation formula for NDSLP.
Work toward standardization of policies among the states with regard to GLP.
Study the impact of borrowing.
Colleges should have adequate aid staffs, OE should offer training.
OE should make 5-year projections of need for loans.
Task force should identify elements involved in forecasting, states shouldmake projections for 5 years of future loan requirements.
Hold meetings to increase attractiveness of revolving fund for loans.
Strengthen state agencies by federal re-insurance, further seed money, lapseof direct federal insurance, etc.
Consider ending subsidy of interest in GLP during repayment period.
Enable OE to enter into agreements with nationwide insurance companies, creditunions, etc. to increase participation of lending institutions.
GSL should be eligible for matching with Educational Opportunity Grants.
Merge Vocational Student Loan Program with GLP.
Revise method for computing loan delinquency.
Adopt effective write-off procedure.
Do not extend forgiveness feature to GLP.
Make loans available to half-time students.
Numerous deferment provisions should be standardized.
Interest payments should be standardized.
Reinbursement to institutions for administrative expense., should be provided.
Provisions affecting cancellations and late payment charges should bestandardized.
Merge Cuban Loan with other programs.
Procedure for allocating NDSLP funds should be revised.
No state allocation should be allowed to lapse.
Special consideration for superior students in NDSLP should be eliminated.
Revise institutional allocatio' procedure for HPSLP.
Appendix C - continued C-3
Disseminate information about availability of nursing loans.
Combine six loan programs into two.
Contradictory Evidence from Survey
Centralize all loan program administration in one federal agency.(Healthprofessions and nursing schools satisfied with PHS.)
NDSLP appropriation should not be cut or increased. (Schools wanted largerappropriations.)
End loan forgiveness for teachers.(Schools favored forgiveness; borrowerssaid forgiveness not a motive for teaching.)
End loan forgiveness for nurses. (Nursing schools favored forgiveness.)
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